HomeMy WebLinkAbout14-0770 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK, THROUGH ITS SERVICING
AGENT, DB SERVICING CORPORATION
Plaintiff No. C v
vs. PRA.ECIPE TO TRANSFER JUDGMENT
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RANDAL E ZEIGLER SR =
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Defendant'
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FILED ON BEHALF OF
Plaintiff 5c� �;:'
COUNSEL OF RECORD OF `
THIS PARTY:
William T Molczan, Esquire
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
1.400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434 -7955
WWR #09721387
$3492.54
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IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, .PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK, THROUGH ITS SERVICING
AGENT, DB SERVICING CORPORATION
Plaintiff
vs. Civil Action No.
RANDAL E ZEIGLER SR
Defendant
PRAECIPE TO TRANSFER JUDGMENT
TO THE PROTHONOTARY:
Please transfer the within Judgment entered in The Court of Common .Pleas of COLUMBIA County,
Pennsylvania, known as No. 2012 -CV -1832, and index it against the Defendant above named, in the amount of
$3492.54 -
COLUMBIA County costs to follow Judgment.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By: X/A ,
William T Molczan, Esqu' e
PA I.D. #47437
WELTMAN, WEINBERG & R.EIS CO., L.P.A.
1.400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434 -7955
WWR #09721387
I hereby certify that the address of the Plaintiff is:
c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7'" Avenue, Pittsburgh, PA 1521.9
And that the last known address of the Defendantis: 3781 SPRING ROAD, SHERMANS DALE, PA 17090
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L.
WELTMAN, WEINBERG & REIS CO., L.P.A.
BY: William T Molczan, Esquire Attorney for Plaintiff(s)
I.D. No. #47437
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
Phone: 412.434.7955
Fax: 412.434.7959
File # 9721387
DISCOVER BANK, THROUGH ITS
SERVICING AGENT, DB SERVICING
CORPORATION
COLUMBIA County
Court of Common Pleas
VS.
RANDAL E ZEIGLER SR
NO. 12- 6674 -CIVIL TERM
ac)19,- Cv _cg 32 �
PRAECIPE FOR EXEMPLIFIED RECORD
• TO THE PROTHONOTARY:
Kindly provide an exemplified record for the judgment entered in the above captioned case in
order to transfer it to Westmoreland County.
WELTMAN, WEINBERG & REIS CO., L.P.A.
B I
Y
William T Molczan squire
Attorney for Plaintiff
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Date: 'y13/2014 Columbia County Court of Common Pleas NO. 0000071
4
Time: 12:12 PM Receipt Page 1 of 1
Received of: Weltman Weinberg & Reis Co LPA $ 22.25
Twenty -Two and 25/100 Dollars
Case: 2012 -CV- 0001832 -JU Plaintiff: Discover Bank vs. Randal E Zeigler Sr Amount
Misc Fee 22.25
Total: 22.25
Payment Method: Cash Barbara N. Silvetti, Prothonotary
Amount Tendered: 22.25
By:
Clerk: MTRAUGH Deputy Clerk
1/13/2014 Columbia County Court of Common Pleas User: MTRAUGH
Time: 12:40 PM Complete Case History
Page 1 of 2 Case: 2012 -CV- 0001832 -JU
Discover Bank vs. Randal E Zeigler Sr
Filed: 12/24/2012
Subtype: Judgment
Physical File: Y Appealed: N
Comment: Money Judgment
Plaintiff
Name: Discover Bank SSN:
Address: DOB:
Sex:
Phone: Home: Work:
Employer: Send notices: Y
Litigant Type:
Comment:
Defendant
Name: Zeigler, Randal E Sr SSN:
Address: 3781 Spring Rd DOB:
Shermans Dale PA 17090 Sex:
Phone: Home: Work:
Employer: Send notices: Y
Litigant Type:
Comment:
Register of Actions
12/24/2012 Filing: Judgment Fee w /Tax Paid by: Judge, No
Wellman Weinberg & Reis Co LPA
Receipt number: 0008494 Dated:
12/24/2012 Amount: $20.50 (Check) For:
Discover Bank (plaintiff)
Praecipe for Judgment by Consent filed by
Atty Weinberg with Stipulation of the
Parties for payment and for the entry of
judgment by consent.
One copy returned to Atty Weinberg by
regular mail.
Judgment is hereby entered in favor of the
Plaintiff and against the Defendant in the
amount of $3,492.54. /s/ Barbara N
Silvetti, Acting Prothonotary.
One copy of all documents filed with
notice of entry of judgment mailed to the
Defendant by regular mail..
1/13/2014 Miscellaneous Payment: Misc Fee Paid Judge, No
by: Wellman Weinberg & Reis Cc LPA
Receipt number: 0000071 Dated:
1/13/2014 Amount: $22.25 (Cash)
Praecipe for Exemplified Record filed by Judge, No
Atty William T. Molczan.
One copy returned to Atty Molczan by
regular mail.
-,Ow ate: �'1/13/2014 Columbia County Court of Common Pleas User: MTRAUGH
Time: 12:40 PM Complete Case History
Page 2 of 2 Case: 2012 -CV- 0001832 -JU
Discover Bank vs. Randal E Zeigler Sr
Judgment
Order date In Favor Of Disposition Judgment
12/24/2012 Plaintiff 00 /00 /0000 Open Money Judgment
Comment: $3,492.54
Plaintiff: Discover Bank
Defendant: Zeigler, Randal E Sr
I hereby certify the within to be a true and correct
opy certified from the record this lS ' day of
2014 Prothonotary /Clerk of Courts
� arb Ira N, Silve t
yr otil & (;ierk of Sev. o
-k4v Com. Ex.1 st Fr ondpov in 2016
I further certify that judgment was entered in favor of the Plaintiff, Discover Bank,
and against the Defendant Randal E. Zeigler, Sr. in the amount'of $3,492.54.
In testimony whereof, I have hereunto set my hand and affixed the Seal of the said Court
on the 13th day of January, 2013.
Prothonotary
By:
Deputy
broth & Clerk of Sev. Courts
A4v Com. Ex.1 st Mo1ndav in 2016
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK, THROUGH ITS SERVICING
AGENT, DB SERVICING CORPORATION
Plaintiff l
vs. Civil Action No. — I n D
RANDAL E ZEIGLER SR
Defendant
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the f llo mg Order or Judgment
was entered against you on
(xx) Assumpsit Judgment in the amount
of $ 3492.54 plus costs.
( ) Trespass Judgment in the amount
of $ plus costs.
( ) If not satisfied within sixty (60) days, your motor vehicle
operator's license and /or registration will be suspended by the
Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA.
(xx) Entry of Judgment of
( ) Court Order
( ) Non -Pros
( ) Confession
( ) Default
( ) . Verdict
( ) - Arbitration
Award
Prothonotary
RANDAL E ZEIGLER By:
3781 SPRING ROAD PROTHONOTARY (OR DEPUTY)
SHERMANS DALE, PA 17090
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK, THROUGH ITS SERVICING AGENT,
DB SERVICING CORPORATION
Plaintiff
vs.
RANDAL E ZEIGLER SR
Defendant(s)
SANTANDER BANK, N.A.
Garnishee(s)
TO THE PROTHONOTARY:
Civil Action No. 14 -770 CIVIL
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 RANDAL E ZEIGLERSR , Defendant
3. against SANTANDER BANK, N.A., , , Garnishee
4. Judgment Amount
Less Payments /credits received
Interest
Costs
SUBTOTAL:
Costs (to be added by Prothonotary):
Q)
$3,492.54 t�
$700.00 ,, 9 d • sN
$219.13
$3,011.67
WELTMAN, WEINBERG & REIS CO., L.P.A.
By: C•
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
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WWR No. 9721387
• -4
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK, THROUGH ITS SERVICING AGENT,
DB SERVICING CORPORATION
Plaintiff
vs.
RANDAL E ZEIGLER SR
Defendant(s)
SANTANDER BANK, N.A.
Garnishees)
No. 14 -770 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 1400
Pittsburgh, PA 15219
(412) 434-7955
WWR No. 9721387
WRIT OF EXECUTION and /or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 14 -770 Civil
CIVIL ACTION — LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DISCOVER BANK, THROUGH ITS SERVICING
AGENT, DB SERVICING CORPORATION Plaintiff (s)
From RANDAL E. ZEIGLER SR., 3781 SPRING ROAD, SHERMANS DALE, PA 17090
(1) You are directed to levy upon the property of the defendant (s)and to sell You are also directed
to attach the property of the defendant(s) not levied upon in the possession
of GARNISHEE(S) as follows:
SANTANDER BANK, N.A., 17 WEST HIGH STREET, CARLISLE, PA 17013
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant(s) and from delivering any property of the
defendant(s) or otherwise disposing thereof;
(2) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he /she has been added as a
garnishee and is enjoined as above stated.
Amount Due $2,792.54
Interest $219.13
Attorney's Comm. %
Attorney Paid $83.00
Other Costs $
Date: MARCH 10, 2014
Plaintiff Paid $
Law Library $.50
Due Prothonotary $2.25
bos„;c2Th
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
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
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Discover Bank Through Its Servicing Agent, DB Servicing Corporation
va.
Randal E. Zeigler, Sr.
Case Number
2O14'770
SHERIFF'S RETURN OF SERVICE
03/12/2014 11:38 AM - Dennis Fry, Deputy, who being duly sworn according to law, attached as herein commanded all
goods, chattels, hghto, debta, nredibe, and monies of the Defendant, in the hendo, pooeession, or control of
the within named ganniohee. Santander Bank, 17VVHigh Straat, Carlisle Borough, Cmdide, PA 17013.
Cumberland County, by handing to Julie Myers, Branch operations 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 March 13, 2014 to Randal Zeigler Sr., at 3781
Spring Road, Shermansdale, PA 17090.
March 13, 2014
(e) CountyStiite Sheriff, Teleesoft
DE IS FRY, DEP
SO ANSWERS,
�ONNYR ANDERSON, SHERIFF
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK, THROUGH ITS SERVICING AGENT,
DB SERVICING CORPORATION
Plaintiff
vs.
RANDAL E ZEIGLER SR
Defendant(s)
SANTANDER BANK, N.A.
Garnishee(s)
Civil Action No. 14 -770 CIVIL
TO: SANTANDER BANK, N.A., 17 W. HIGH ST, CARLISE, PA 17013
RE: RANDAL E ZEIGLER SR, 3781 SPRING RD, SHERMANS DALE, PA 17090
Suggested Reference No.: XXX -XX -3324
XXX -XX- A `^ i
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. 9721387
Account #
ANSWERS TO INTERROGATORIES
7678520107 Balance: $2,510.80
After allowing for the $300.00 exemption under 42 Pa.C.S. 8123 the balance in this
account is $2,210.80.
Account Holder:
TRISHA J ZEIGLER
RANDAL ZEIGLER
3781 SPRING RD
CARLISLE, PA 17013
VERIFICATION
I, John S. Gomes, C.O.P. Lead Specialist of Santander, hereby verify that the
information contained in the foregoing Answers to Interrogatories in Attachment are true
and correct to the best of my knowledge, information and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. Section 4094,
relating to unsworn falsification to authorities.
John S. Gomes
C.O.P. Lead Specialist
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK, THROUGH ITS SERVICING AGENT,
DB SERVICING CORPORATION
Plaintiff
VS.
RANDAL E ZEIGLER SR
Defendant(s)
SANTANDER BANK, N.A.
Garnishee(s)
Civil Action No. 14-770 CIVIL
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. 9721387
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 sayirigs-aeeounts and certificates of "
deposit) ?:' -
NO
l 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.
N/A
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.
YES, SEE ATTACHED
3. At the time you were served or at any subsequent time did you hold legal title to any property of
any nature owned solely or part by the defendant or in which defendant held or claimed any interest?
NO
4. At the time you were served or at any subsequent time did you hold as fiduciary any property in
which the defendant had an interest?
NO
5. At any time before or after you were served, did the defendant transfer or deliver any property to
you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof?
NO
6. At any time after you were served did you pay, transfer, or deliver any money or property to the
defendant; or to any person or place pursuant to his direction or otherwise discharge any claim of the defendant
against you?
NO
7. If you are a bank or other financial institution, at the time you were served or at any subsequent
time did the defendant have funds on deposit in an account in which funds are deposited electronically on a
recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or
attachment under Pennsylvania or federal law? If so, Identify each account and state the reason for the exemption,
the amount being withheld under each exemption and the amount of funds in each account, and the entity
electronically depositing those funds on a recurring basis.
NO
WWR No. 9721387
$; If you are a bank or other financial institution, at the time you were served or at any subsequent
time did the defendant have funds on deposit in an account in which the funds on deposit, not including any
otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If
so, identify each account.
NO
9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these
interrogatories on this institution.
N/A
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.
N/A
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?
N/A
12. If the response to Interrogatory 11 is in the affirmative, state the amount of non- exempt funds on
deposit in the account.
N/A
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`h Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434 -7955
WWR No. 9721387
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 JOHN S. GOMES
LEAD SPECIALIST
(Name)
of SANTANDER BANK , garnishee herein,
(Title) (Company)
that he /she is duly authorized to make this verification, and that the facts set forth in the foregoing
Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief.
WWR No. 9721387
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
IN RE:
DISCOVER BANK THROUGH ITS SERVICING AGENT DB SERVICING
CORPORATION
vs.
RANDAL ZEIGLER
CERTIFICATE OF SERVICE
I hereby certify that on or before the date of filing the following documents(s):
Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of
Execution, Claim for Exemption Order and Claim for Exemption
I have served a copy thereof on each of the following persons in the manner
indicated below:
Service by first class mail addressed as follows:
JAMES P. VALECKO, ESQ
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 7TH AVE SUITE 1400
PITTSBURGH, PA 15219
Service by certified mail addressed as follows:
RANDAL ZEIGLER
3781 SPRING RD
CARLISLE, PA 17013
/ I 1
i1vImm
J . hn S. Gomes
.O.P. Lead Specialist
Santander
MA1 MB3 -02 -10
2 Morrisey Boulevard
Boston, MA 02125
March 24, 2014
THE i.. t:
F 1'&E
2014 APP -1 Pik 4. 12
. 'BLAND COUNTY, PENNSYLVANIA
IN THE COURT OF COMMON'1�k ISION
DISCOVER BANK,
THROUGH ITS SERVICING AGENT,
DB SERVICING CORPORATION
Plaintiff
vs.
RANDAL E ZEIGLER SR
Defendant
SANTANDER BANK, N.A.
Garnishee
No. 14- 770 -CIVIL
PRAECIPE FOR JUDGMENT AGAINST
GARNISHEE
FILED ON BEHALF OF
Plaintiff
COUNSEL OF.RECORD.OF •
THIS PARTY:
William T. Molczan Esquire
PA 1.D. #47437
Weltman, Weinberg & Reis Co., L.P.A.
1400 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR #09721387
,. •
• IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK, THROUGH ITS SERVICING AGENT,
DB SERVICING CORPORATION
Plaintiff
VS.
RANDAL E ZEIGLER SR
Defendant(s)
SANTANDER BANK, N.A.
Garnishee(s)
Civil Action No. 14-770 CIVIL
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. 9721387
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK, THROUGH ITS SERVICING AGENT,
DB SERVICING CORPORA]. ION -
Plaintiff
VS.
RANDAL E ZEIGLER SR
Defendant(s)
SANTANDER BANK, N.A.
Garnishee(s)
Civil Action No. 14-770 CIVIL
TO: SANTANDER BANK, N.A., 17 W. HIGH ST, CARLISE, PA 17013
RANDAL E ZEIGLER SR, 3781 SPRING RD, SHERMANS DALE, PA 17090
Suggested Reference No.:
XXX-X.X-3324
XXX-XX-
IMPORTANT NOTICES TO GARNTISIIEE!
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 subjecto
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. 9721387
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK, THROUGH ITS SERVICING AGENT,
DB SERVICING CORPORATION
Plaintiff
VS.
RANDAL E ZEIGLER SR
Defendant(s)
SANTANDER BANK, N.A.
Garnishee(s)
Civil Action No. 14-770 CIVIL
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 rh Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434-7955
WWR No. 9721387
`
INTE4ROGATORIES
IN ATTACHMENT ' '
l. At the time you were aurved or at any subsequent time did you owe the defendant any money or
were you liable to him on any negotiable negotiable or �ther 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 �r savings :dObouot»aridbCttifioa±cSof
deposit)?
NO
la. If the answer to Interrogatory 1 is in the affirmative state the the amount
of money you owe or owed to d 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.
N/A
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.
YES, SEE ATTACHED
3. At the time you were served or at any subsequent time did you hold legal title to any property of
any nature owned solely or part by the defendant or in which defendant held or claimed any interest?
NO
4. At the time you were served or at any subsequent time did you hold as fiduciary any property in
which the defendant had an interest?
—NO
5. At any time before or after you were served, did the defendant transfer or deliver any property to
you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof?
NO
6. At any time after you were served did you pay, transfer, or deliver any money or property to the
defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the defendant
against you?
NO
7. If you are abank 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.
NO
WWR No. 9721387
$i If you are a bank or other financial institution, at the time you were served or at any subsequent
time did the defendant have funds on deposit in an account in which the funds on deposit, not including any
otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If
so, identify each account.
NO
9. If the answer to Interrogatory I is in the affirmative, state the date the sheriff served these
interrogatories on this institution.
N/A
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.
N/A
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?
N/A
12. If the response to Interrogatory 11 is in the affirmative, state the amount of non - exempt funds on
deposit in the account.
N/A
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
James P. alecko, Esquire
PA I.D. # 9596
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 7th Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434 -7955
WWR No. 9721387
Account #
ANSWERS TO INTERROGATORIES
7678520107 Balance: $2,510.80
After allowing for the $300.00 exemption under 42 Pa.C.S. 8123 the balance in this
account is $2,210.80.
Account Holder:
TRISHA J ZEIGLER
RANDAL ZEIGLER
3781 SPRING RD
CARLISLE, PA 17013
VERIFICATION
I, John S. Gomes, C.O.P. Lead Specialist of Santander, hereby verify that the
information contained in the foregoing Answers to Interrogatories in Attachment are true
and correct to the best of my knowledge, information and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. Section 4094,
relating to unsworn falSifitati-oh to aUtho-fitie-s: --
Santander
By:
/
John S. Gomes
C.O.P. Lead Specialist
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 JOHN S . GOMES
(Name)
LEAD SPECIALIST
(Title)
of SANTANDER BANK , garnishee herein,
(Company)
that he /she is duly authorized to make this verification, and that the facts set forth in the foregoing
Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief.
WWR No. 9721387
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
IN RE:
DISCOVER BANK THROUGH ITS SERVICING AGENT DB SERVICING
CORPORATION
VS.
RANDAL ZEIGLER
CERTIFICATE OF SERVICE
I hereby certify that on or before the date of filing the following documents(s):
Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of
Execution, Claim for Exemption Order and Claim for Exemption
I have served a copy thereof on each of the following persons in the manner
indicated below:
Service by first class mail addressed as follows:
JAMES P. VALECKO, ESQ
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 7TH AVE SUITE 1400
PITTSBURGH, PA 15219
Service by certified mail addressed as follows:
RANDAL ZEIGLER
3781 SPRING RD
CARLISLE, PA 17013
hn S. Gomes
.0.P. Lead Specialist
Santander
MA1 MB3-02-10
2 Morrisey Boulevard
Boston, MA 02125
March 24, 2014
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK,
THROUGH ITS SERVICING AGENT,
DB SERVICING CORPORATION
Plaintiff
vs.
RANDAL E ZEIGLER SR
Defendant
SANTANDER BANK, N.A.
Garnishee
Santander Bank, N.A.
Court Order Processing
MAI-MB3-02-10
P.O. BOX 841005
BOSTON, MA 02284
Civil Action No. 14-770-CIVIL
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
( ) Defendant
(xx) Garnishee
You are hereby notified that the following
Order or Judgme t w s entered against
you on 11
(xx) Assumpsit Judgment in the amount
of $2,210.80 plus costs.
( )
Trespass Judgment in the amount
of $ plus costs.
( ) If not satisfied within sixty (60)
days, your motor vehicle operator's license and/or registration will be
suspended by the Department of Transportation, Bureau of Traffic Safety,
Harrisburg, PA.
(xx) Entry of Judgment of
( ) Court Order
( ) Non-Pros
( ) Confession
( ) Default
( ) .Verdict
( ) Arbitration
Award
Prothonotary
By:
PROTHONOTARY (OR DEPUTY)
WELTMAN, WEINBERG & REIS CO., L.P.A.
BY: James P Valecko Esquire Attorney for Plaintiff(s)
I.D. No.79596
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
Phone: 412.434.7955
Fax: 412.434.7959
File # 9721387
DISCOVER BANK
Cumberland County
Court of Common Pleas
vs.
RANDAL E ZEIGLER SR
NO. 14 -770 CIVIL
and
SANTANDER BANK, N.A.
Garnishee(s)
PRAECIPE TO SATISFY ATTACHMENT EXECUTION
121__
CO
C.'
:
car
TO THE PROTHONOTARY:
Kindly marked the above matter satisfied as to Garnishee(s), SANTANDER BANK, N.A.,
only.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By
�1
James P alecko, Esquire
Attorney or
Plaintiff
a ntiff
<49. Ca
c4/7/s7779a
ok 303-07
—�w
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY,
Cts- THE PROTHONOTAV
2 =1 OCT - AMU: I: 15
CUMBERLAND COUNTY
PENNSYLVANIA
Discover Bank Through Its Servicing Agent, DB Servicing Corporation
vs.
Randal E. Zeigler, Sr.
Case Number
2014-770
SHERIFF'S RETURN OF SERVICE
03/12/2014 11:38 AM - Dennis Fry, 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, Santander Bank, 17 W High Street, Carlisle Borough, Carlisle, PA
17013, Cumberland County, by handing to Julie Myers, Branch operations 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 March 13, 2014 to Randal Zeigler Sr., at
3781 Spring Road, Shermansdale, PA 17090.
10/08/2014 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is
returned as ABANDONED. No action on writ in over 6 months.
SHERIFF COST: $88.76 SO ANSWERS,
October 08, 2014
(c) CountySuite Sheriff, Teleosoft, bac.
RONNS' R ANDERSON, SHERIFF