HomeMy WebLinkAbout14-5107 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DAIMLERCHRYSLER FINANCIAL SERVICES
AMERICAS LLC
Plaintiff No. 51t)q
vs. PRAECIPE TO FILE FOREIGN JUDC'MEN�,
= �
NANCY E ROCCISANO � rT1
Defendant cnr i
FILED ON BEHALF OFr ,+
Plaintiff
c rt
CD
COUNSEL OF RECORD OF
THIS PARTY:
Matthew D. Urban, Esquire
PA I.D. #90963
Weltman, Weinberg, & Reis, CO., L.P.A.
436 Seventh Avenue, Suite 2500
Pittsburgh, PA 15219
Phone: (412)434-7955
WWR#20538635
433.50 PA A�
ars III 36o5q
0 -51008
Ace Hai Iec(
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DAIMLERCHRYSLER FINANCIAL SERVICES
AMERICAS LLC
Plaintiff
vs. Civil Action No. jq_ 5767 67 6i
NANCY E ROCCISANO
Defendant
PRAECIPE TO FILE FOREIGN JUDGMENT
TO THE PROTHONOTARY:
Please file the enclosed certified transcript of Judgment Entry from the Supreme Court of the
State of New York, County of Orange in accordance with Section B of the Uniform Enforcement of
Foreign Judgment Act(42 Pa. C.S.A. Section 4306), and also mail notice of the filing of the Judgment to
the Judgment-debtor at the address shown on the attached verification.
Amount of Judgment computed as follows:
Damages: $20,723.65
Total Judgment $20,723.65
WELTMAN, WEINBERG & REIS CO., L.P.A.
Date:
By:
Matthew D. Urban, Esquire
PA I.D. #90963
Weltman, Weinberg, & Reis, CO., L.P.A.
436 Seventh Avenue, Suite 2500
Pittsburgh, PA 15219
Phone: (412)434-7955
WWR#20538635
4 ,
State: PENNSYLVANIA
County: ALLEGHENY
AFFIDAVIT
Before me, the undersigned notary public, personally appeared, Matthew D. Urban, Esquire, to
me known or proven, who being duly sworn according to law, doth depose and say that he/she is the
attorney for the Judgment Creditor, DaimlerChrysler Financial Services Americas LLC; that the last known
address of the Judgment Debtor, Nancy E. Roccisano, is 52 Eastwick Lane, Carlisle, PA 17015; that the
last known address of the Judgment Creditor, DaimlerChrysler Financial Services Americas LLC is 4600
Touchton Road, Bldg 200, Suite 400, Jacksonville, FL 32246; that the Foreign Judgment is valid,
enforceable and unsatisfied, and that the facts set forth in the foregoing Praecipe are true and correct to
the best of the undersigned's knowledge, information and belief.
Date: 2 L4
Matthew D. Urban, Attorney for Plaintiff
Sworn and subscribed
Before me this 2-1(o COMMONWEALTH OF PENNSYLVANIA
NOTARIAL SEAL
Day of S 2014 Wendy L.Gault.Notary Public
City of Pittsburgh,Allegheny County
My Commission Expires July 15.2018
MEMBER,PENNSYLVANIA ASSOGIA ION OF NOTARIES
Not2fy Public
CERTIFICATE OF EXEMPLIFICATION
WE HAVE CAUSED THESE PRESENTS TO BE EXEMPLIFIED,AND AFFIX THE SEAL OF
THE SUPREME COURT OF THE STATE OF NEW YORK.
WITNESS,HON. ANDREW P. BIVONA,ONE OF THE JUSTICES OF THE SUPREME
COURT OF THE STATE OF NEW YORK. _ r
DATED: a 0�0(� C`� Ll�' a. l
KELLY A. ESKEW
DEPUTY COUNTY CLERK
I, HON. ANDREW P. BIVONA ONE OF THE JUSTICES OF THE SUPREME COURT OF
THE STATE OF NEW YORK, DO HEREBY CERTIFY THAT KELLY A. ESKEW IS
DEPUTY COUNTY CLERK OF THE NEW YORK STATE SUPREME COURT ORANGE
COUNTY,NEW YORK AND IS DULY APPOINTED AND SWORN AND THAT FULL
FAITH AND CREDIT ARE DUE HER OFFICIAL ACTS. I FURTHER CERTIFY THAT THE
SEAL AFFIXED TO THE EXEMPLIFICATION IS THE SEAL OF OUR SUPREME COURT
AND THAT THE ATTESTATION THEREOF IS IN DUE FORM.
DATED:_6 - -)L -7 - c-- bb/ ,
GOSHEN,NEW YORK ON. ANDREW P. B VONA
SUPREME COURT JUSTICE
STATE OF NEW YORK]
:SS:
COUNTY OF ORANGE ]
I, KELLY A. ESKEW CLERK OF THE SUPREME COURT OF THE STATE
OF NEW YORK, COUNTY OF ORANGE, DO HEREBY CERTIFY THAT
HON. ANDREW P. BIVONA IS ONE OF THE JUSTICES OF THE SUPREME COURT OF
THE STATE OF NEW YORK,NINTH JUDICIAL DISTRICT, COUNTY OF ORANGE,DULY
ELECTED AND SWORN.
IN WITNESS WHEREOF,I HAVE SET MY HAND AND SEAL THIS DATE.
DATED: ��-
KELLY A. W
DEPUTY COUNTY CLERK
• s r , i ���IU����UII�IIN�IIIII IIII�11
000000178537
• -SUPREME COURT OF THE STATE OF NEW YORK R & R File No. 546820
COUNTY OF ORANGE Client Acct: 7001659005
---------------------------------------- S 071
DAIMLERCHRYSLER FINANCIAL SERVICES
AMERICAS LLC
-against- PlaintiffJUDGMENT
NANCY E ROCCISANO
Index No. 3369-2007
Defendant(s)
----------------------------------------
Amount claimed in complaint . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . $ 20,723.65
Interest . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .00
---------
TOTAL $ 20,723.65
Costs by Statute. . . . . . . . . . . . . . . . . . . . . . . . . . . $ 200.00
Service of process. . . . . . . . . . . . . . . . . . . . . . . . . 25.00
Fee for Index Number. . 210.00
Prospective execution fee. . . . . . . . . . . . . . . . . . 20.00
455.00
------------
TOTAL $ 21,178.65
STATE OF NEW YORK, COUNTY OF SUFFOLK:
The undersigned, an attorney admitted to ractice in the State of New York,
associated with the attorneys for plaintiff, undeY penalties of perjury,
affirms the following.to be true: The disbursements specified above have
been or will necessarily be made or incurred and are reasonable in amount.
Defendants) have failed to appear, answer or move herein, and the time to
do so having expired, plaintiff is entitled to judgment by default.
A copy of the summons was deposited on 6/18/07 (Deft 1)
in a separate ost paidenvelo a in an official depository of the United
States Postal gervice within New York State, addressed to each defaulting
defendant's last known home address set forth herein. More than 20 days
have elapsed and the envelope has not been returned as undeliverable
byy the ppoost office.
CPLR 4539(b) ALLOWS REPRODUCTION OF DOCUMENTS IN ACCORDAN4TWH
HE
REQUIREMENTS SET FORTH THEREIN. THE DOCUMENTS SUBMITTED
JUDGMENT ARE EITHER ORIGINALS OR IDENTICAL TO THE ORIGINA
REPRODUCTION, THE ORIGINAL WAS STORED ELECTRONICALLY IN AMANY)
• CREATES TIF IMAGES AND RECORDS THEM IN A WORM (WRITE ONCE
CD SYSTEM. INFORMATION STORED IN A WORM CD SYSTEM CANNOTED
ONCE IT IS RECORDED.
Dated: August 6, 2007
FRANCIS N. ANDERSONSA
RUBIN & ROTHM
Attorneys for Plaintiff
1787 Veterans Highway
Islandia, N.Y. 11749
(631) 234-1500
NOW, on motion of Rubin and Rothman, LLC, it is adjudged that
DAIMLERCHRYSLER FINANCIAL SERVICES AMERICAS LLC
located at 4600 TOUCHTON RD. BLDG 200, STE 400, JACKSONVILLE, FL 32246
recover of NANCY E ROCCISANO
residing at 5263 SEARSVILLE RD, PINE BUSH, NY 12566
the sum of $ 21,178.65 and that the laintiff have execution therefor.
Dated: '163-2-0-07 _ &MA
-------ACTING DE�N>~tUFKORANGE)OS �rk
1,ANN G.BABBITT,COUNTY CLERK AND CLERK OF THE
RECORDED/FILED ORANrt COUNTY SUPREME AND COUNTY COURTS,ORANGE COUNTY,00
BOOK 08045 PAGE 1 Q 15 HERE CERTIFY THAT I HAVE COMPARED THIS COPY WITH
B OK 1/2807/ 14;P i:55 TH IGINA THEREOF FILED OR RECORDED IN MY OFFICE
FILE t4UMBER 2001�1i09i:0c c^^
0 ) 20 dOO7 AND THE SAME)S A CORRECT
RECEIPT#777378 �I,j k T NSC PT THER7`OE IN WITNESS WHEREOF,t HAVE
HERE 0 SET MY HAND AND AFFIXED MY OFFICIAL SEAL.
-exll�
COUNTY CLERIC&CLERK OF THE SUPREME COUNTY COURTS,
()RANGE COUNTY
**** TRANSCRIPT OF JUDGMENT ****
JUDGMENT DEBTOR JUDGMENT CREDITOR
Surname/Given Name and Address Surname/Given Name and Address
ROCCISANO NANCY E DAIMLERCHRY LER FINANCIAL SVCS AMER]
5263 SEARSVILLE RD 4600 TOUCHTON RD BLDG 200 STE 400
PINE BUSH NY 12566 JACKSONVILLE FL 32246
Judgment Docketed Judgment Rendered Amount of Judgment Attoj
File Date/Time: 8/20/2007 14:21:55 County: ORANGE Damage: RUBS
Instrument Number: 20070092022 Court Type: SUPREME Cost .
Index Number&Case Type: Perfected Date/Time: 08/20/2007 14:21:00 Total :$ 21,178.65 1787
003369-2007 CIV IBCA{
STATE OF NEW YORK,COUNTY OF ORANGE
I,ANN G.RABBITT,COUNTY CLERK,Clerk of the County of Orange,hereby certify ti
the above is a correct transcript of judgments in my office.
IN WITNESS THEREOF,I have hereunto set my name and affixed my seal
this 26TH day of JULY,2014. J
KELLY A�
DEPUTY
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DAIMLERCHRYSLER FINANCIAL SERVICES
AMERICAS LLC
Plaintiff
vs. Civil Action No.
NANCY E ROCCISANO
Defendant
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that
the following Order or
Judgment Waentered against
you on qldllq
(xx) Assumpsit Judgment in the amount
of$20,723.65 plus interest and costs.
( ) Trespass Judgment in the amount
of$ 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 A
Prothonotary
By:
PROTHONOTARY (OR DEPUTY)
NANCY E ROCCISANO
52 EASTWICK LANE
CARLISLE,PA 17015
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
ova, DIVISION
DAIMLERCHRYSLER FINANCIAL SERVICES
AMERICAS LLC
Plaintiff
vs.
NANCY E ROCCISANO
Defendant(s)
CITIZENS BANK
WELLS FARGO BANK
PNC BANK,
Garnishee(s)
No. 14-5107 CIVIL TERM
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 7thAvenue, Suite 2500
Pittsburgh, PA 15219
(412) 434-7955
WWR No. 20538635
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DAINILERCHRYSLER FINANCIAL SERVICES
AMERICAS LLC
Plaintiff
vs.
Civil Action No. 14-5107 CIVIL TERM
NANCY E ROCCISANO 5a Eai.1.,oic.lciane,0...arlible PA 1170(5
Defendant(s)
CITIZENS BANK- 1pto5 N. East 54, ea H is le PA Ir1013
WELLS FARGO BANK - (004 E. Hish B+, aarli5le Pik I (701-5
PNC BANK - lOs Node PAci3O..arlide l'7D13
Garnishee(s)
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Kindly issue a Writ of Execution in the above matter...
1. directed to the Sheriff of CUMBERLAND County:
2. against NANCY E ROCCISANO , Defendant
3. against CITIZENS BANK, WELLS FARGO BANK, PNC BANK, Garnishee
4. Judgment Amount $20,723.65
C)
-0 X
MI CD
m
c.r)
r-
< CD
Less Payments/credits received
Interest
Costs
SUBTOTAL: $20,846.29
Costs (to be added by Prothonotary):
() WELTMAN, WEINBERG & REIS CO., L.P.A.
$ $0.00
$122.64
* c9A 00 PD
I-155. 00 C1SF By:
33..50 James P. Va lcko, Esquire
PA I.D. #79 96
.`-$ 517.5D - P0 AIT WELTMAN, WEINBERG & REIS CO., L.P.A.
436 7t Avenue, Suite 2500
Pittsburgh, PA 15219
(412) 434-7955
c1-9,25 auLeo
' SO LL
iliqaDq5
Rp3,0745
bori-i-opEvA-suuPt
WWR No. 20538635
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
DAIMLERCHRYSLER FINANCIAL SERVICES
AMERICAS LLC
Vs.
NANCY E. ROCCISANO
WRIT OF EXECUTION
(Pa R.C.P. 3252)
NO 14-5107 Civil Term
CIVIL ACTION — LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the judgment, interest and costs against NANCY E. ROCCISANO, 52 Eastwick Lane, Carlisle,
PA 17015 Defendant (s)
(1) you are directed to levy upon the property of the defendant (s) and to sell the defendant (s) interest therein;
(2) you are also directed to attach the property of the defendant (s) not levied upon in the possession of
CITIZENS BANK, 665 N. East Street, Carlisle, PA 17013
WELLS FARGO BANK, 604 E. High Street, Carlisle, PA 17013
PNC BANK, 105 Noble Blvd, Carlisle, PA 17013
GARNISHEE(S), as garnishee, (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
1
determined by the executing officer. The funds shall be set aside pursuant to the defendant (s) general
exemption provided in 42 Pa.C.S. § 8123.
(3) if property of the defendant (s) not levied upon and subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify such other person that he or she has been added
as a garnishee and is enjoined as above stated.
Amount Due $20,723.65
Interest -- $122.64
Attorney's Comm. %
Attorney Paid $517.50
Date: 10/20/14
Plaintiff Paid
Law Library $.50
Due Prothonotary $2.25
Other Costs
LaiL,
David D. Buell, Prothonotary
REQUESTING PARTY:
Name : JAMES P. VALECKO, ESQUIRE
Address: WELTMAN, WEINBERG & REIS CO, LPA
436 7TH AVENUE, SUITE 2500
PITTSBURGH, PA 15219
Attorney for: PLAINTIFF
Telephone: 412-434-7955
Supreme Court ID No.
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
FILED -OFF
01 Climb 0- /HE PFIO TI-PONO -11Th i•
oFrICE OF THF: $H�FIFF
ZVI NOV -4 Ate 10: 45
CUMBERLAND COUNT'1.
PENNSYLVANIA
Daimler Chrysler Financial Services Americas LLC
vs.
Nancy E Roccisano
Case Number
2014-5107
SHERIFF'S RETURN OF SERVICE
10/29/2014 09:01 AM - William Cline, Deputy, who being duly sworn according to law, attached as herein commanded
all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control
of the within named garnishee, Citizens Bank, 665 North East Street, Carlisle Borough, Carlisle, PA 17013,
Cumberland County, by handing to Rebecca Winter, Banker, personally three copies of interrogatories
together with three true and attested copies of the Writ of Execution and made the c. tents there of known
to her.
-+� LIAM CLINE, DEPUTY
SO ANSWERS,
October 31, 2014 RONNY R ANDERSON, SHERIFF
(CI CountySuite Sheriff, Teleoset 'no.
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
THE PRO T HONO'+,A.W,:
ZO 14 NOV .-14 A? IC: 45
CUMBERLAND COUNTY
PENNSYLVANIA
()Mc:7;E OF THE HEFIFF
Daimler Chrysler Financial Services Americas LLC
vs.
Nancy E Roccisano
Case Number
2014-5107
SHERIFF'S RETURN OF SERVICE
10/29/2014 12:01 PM - William Cline, Deputy, who being duly sworn according to law, attached as herein commanded
all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control
of the within named garnishee, Wells Fargo Bank, 604 East High Street, Carlisle Borough, Carlisle, PA
17013, Cumberland County, by handing to Jennifner Hommerbocker, Manager, personally three copies of
interrogatories together with three true and attested copies of the Writ of Exec on d made the contents
there of known to her.
October 31, 2014
(c) CountySuito Sheriff Teleosoft,) c.
SO ANSWERS,
, DEPUTY
RONN R ANDERSON, SHERIFF
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND CO JN,TYtFFicr
THE tPROTHONO TA,f
2014NOV -4 10: 45
CUMBERLAND COUNTY
PENNSYLVANIA
Daimler Chrysler Financial Services Americas LLC
vs.
Nancy E Roccisano
Case Number
2014-5107
SHERIFF'S RETURN OF SERVICE
10/29/2014 12:21 PM - William Cline, Deputy, who being duly sworn according to law, attached as herein commanded
all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control
of the within named garnishee, PNC Bank, 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013,
Cumberland County, by handing to Carla Crozier, Sales, personally three copies of interrogatories together
with three true and attested copies of the Writ of Execution and made the contents there of known to her.
The writ of execution and notice to defendant was mailed on October 31, 2014 to ,=ncy Roccisano at 52
Eastwick Lane, Carlisle, PA 17015.
IAM CLINE, D UTY
SO ANSWERS,
October 31, 2014 RONf' R ANDERSON, SHERIFF
(c) CountySuite Sheriff, Tcieosoft. Inc.
SIRLIN LESSER & BENSON, P.C.
By: Jon C. Sirlin, Esquire
Identification No.: 17498
123 South Broad Street, Suite 2100
Philadelphia, PA 19109
(215) 864-9700
Attorney for Garnishee
2t7IL
DAIMLERCHRYSLER FINANCIAL : COURT OF COMMON PLEAS
SERIVICES AMERICAS, LLC : COUNTY OF CUMBERLAND
vs.
NANCY E. ROCCISANO : NO. 14-5107
and
WELLS FARGO BANK, GARNISHEE
ENTRY OF APPEARANCE
TO THE PROTHONOTARY:
Kindly enter my appearance on behalf Wells Fargo Bank, Garnishee in the above -
captioned matter.
Date: \\—,S --0A
SIRI,LN LESSER & BENSON, P.C.
By: Jon C. Sirlin, Esquire
Identification No.: 17498
123 South Broad Street, Suite 2100
Philadelphia, PA 19109
(215) 864-9700
Attorney for Garnishee
2 2:X15
DAIMLERCHRYSLER FINANCIAL : COURT OF COMMON PLEAS
SERIVICES AMERICAS, LLC
vs.
: COUNTY OF CUMBERLAND
NANCY E. ROCCISANO : NO. 14-5107
and
WELLS FARGO BANK, GARNISHEE
ANSWERS TO INTERROGATORIES IN ATTACHMENT
TO: DAIMLERCHRYSLER FINANCIAL SERIVICES AMERICAS, LLC, Plaintiff
1.- 6. Wells Fargo Bank holds no assets of and owes no debt to the Judgment Debtor
herein.
Dated: `\ `1r\I\
Wells Fargo Bank, N.A.
Liens, Levies & Garnishments
101 N. Independence Mall East
MAC Code# Y1372-113
Philadelphia, PA 19106
VERIFICATION
Ednita Johnson, being duly sworn according to law, deposes and says that she is the
Legal Order Processing Associate of Wells Fargo Bank, NA Garnishee herein, and
verifies that the statements made in the foregoing Answers to Interrogatories are true
and correct to the best of her knowledge. Said Garnishee understands that false
statements herein are made subject to penalties of 18 Pa. C.S. Section 4904, relating to
sworn falsification to authorities.
Ednit hnson
Legal der Processing Associate
Date: deeY
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL DIVISION
DAIMLERCHRYSLER FINANCIAL
SERVICES AMERICAS LLC
Plaintiff(s),
vs.
NANCY E ROCCISANO
14-5107
........% -,.,,, „.,,,... r...,„
Defendant(s),
and
Citizens Bank of Pennsylvania,
Garnishee.
ANSWERS TO INTERROGATORIES OF GARNISHEE, CITIZENS BANK
The Garnishee, Citizens Bank of Pennsylvania responds as follows to the Interrogatories of
the Plaintiff(s):
(NUMBERS 1 to 12) At the time of service of above -captioned Writ of Execution and to the
present, Citizens Bank of Pennsylvania, provides the following Answers to Interrogatories:
The Garnishee, Citizens Bank of Pennsylvania, states that it maintains no record of any
deposit account in the name of the defendant, NANCY E ROCCISANO, accordingly, no
funds are being held subject to this Writ of Execution.
(SA
COMMONWEALTH OF PENNSYLVANIA )
) SS:
COUNTY OF ALLEGHENY
Before me, the undersigned authority, a Notary Public in and for said
Commonwealth and County, personally appeared Heather Zito who being duly sworn
according to the law deposes and says that she is the Operations Clerk, Operations Services,
and that the statements set forth in foregoing Answers to Interrogatories are true and correct
to the best of her knowledge, information, and belief.
Sworn and subscribed before
me this L3 day of
0 , 2014.
F
eather Zito
1.,•111! PE".111(Vf7iVANIA
koti,rot Seal
4n,t, Nutary PubEiC
t-tt A AE,c,liteny County
22, 2016
Certificate of Service
I, Heather Zito, hereby certify that a true and correct copy of the Answers to
Interrogatories has been served upon the following by depositing it in the U. S. Mail, postage
prepaid, this 13 day of NOVEMBER, 2014.
JAMES P VALECKO, ESQ
WELTMAN, WEINBERG & REIS CO,
LPA
436 7TH AVE
PITTSBURGH, PA 15219
eather Zito
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA
CIVIL DIVISION
DAIMLERCHRYSLER FINANCIAL
SERVICES AMERICAS LLC,
Plaintiff(s),
vs.
NANCY E ROCCISANO,
Defendant(s),
vs.
Citizens Bank of Pennsylvania,
Garnishee.
14-5107
Answers to Interrogatories
Code: 200 Execution
Filed on Behalf of Garnishee,
Citizens Bank of Pennsylvania
Counsel of Record for
this Party:
Nicholas Deenis, Esquire
PA I.D. No. 62378
Stradley, Ronon, Stevens & Young
2005 Market Street, Suite 2600
Philadelphia PA 19103
(215) 564-8672
(215) 564-8120 fax
ndeenis@stradley.corn
www.stradley.com
WELTMAN, WEINBERG & REIS CO., L.P.A.
BY: William T Molczan, Esquire
I.D. No. 47437
436 Seventh Avenue, Suite 2500
Pittsburgh, PA 15219
Phone: 412.434.7955
Fax: 412.434.7959
File # 20538635
DAIMLERCHRYSLER FINANCIAL
SERVICES AMERICAS, LLC
Attorney for Plaintiff(s)
Cumberland County
Court of Common Pleas
vs.
NANCY E ROCCISANO
and
CITIZENS BANK, WELLS FARGO BANK, PNC BANK
Garnishee(s)
PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION
NO. 14-5107 CIVIL TERM
TO THE PROTHONOTARY:
Kindly mark the above matter discontinued and ended as to Garnishee(s), CITIZENS BANK,
WELLS FARGO BANK, PNC BANK, only.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By
1
William T Molcza . squire
Attorney for Plai'f
sbpd
04# /I F39; Zi
R41- Iluoco
WELTMAN, WEINBERG & REIS CO., L.P.A.
BY: James P Valecko, Esquire Attorney for Plaintiff(s); ;:
I.D. No. 79596
436 Seventh Avenue, Suite 2500
Pittsburgh, PA 15219
Phone: 412.434.7955
Fax: 412.434.7959
File # 20044685
MIDLAND FUNDING LLC
Cumberland County
Court of Common Pleas
vs.
SETH ANDERSON
and
PNC BANK, ACNB BANK
Garnishee(s)
PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION
NO. 14-5686 CIVIL
TO THE PROTHONOTARY:
Kindly mark the above matter discontinued and ended as to Garnishee(s), PNC BANK,
ACNB BANK, only.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By J'
Ja es P Valecko, Esquire
Attorney for Plaintiff
ath,
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