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HomeMy WebLinkAbout05-5050A r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: c$ - S;n56 vs. COMPLAINT IN CIVIL ACTION AMY ORT-RAYMOND AKA AMY L ORT-RAYMOND Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 04469059 C A Pit WLG IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No v-S- 0-t"Z AMY ORT-RAYMOND 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 COMPLAINT 1. Plaintiff, is a corporation with offices at 3311 MILL MEADOW DR. HILLIARD , OH 43026 . 2. Defendant is adult individual(s) residing at the address listed below: AMY ORT-RAYMOND 321 4TH ST # B NEW CUMBERLAND, PA 17070 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011002730617685 . A copy of Plaintiff's Statement of Account s attached hereto, marked as Exhibit "A" and made a part hereof. 4. Defendant made use of said credit card and currently has a balance due and owing to Plaintiff, as of September 15, 2005 , in the amount of $3700.00 . 5. Defendant is in default by failing to make payments when due. 6. Plaintiff avers that the Agreement between the parties provides that Defendant will pay Plaintiff's attorneys' fees. 7. Plaintiff avers that such attorneys' fees will amount to $500.00 . 8. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for Judgment in its favor and against Defendant , AMY ORT-RAYMOND INDIVIDUALLY , in the amount of $3700.00 with interest at the legal rate of 6.000% per annum from date of judgment plus attorneys' fees of $500.00 , and costs. Warmbrod ,425 WEINBERG & REIS CO., L.P.A. th Avenue, Suite 2718 h, PA 15219 -7955 fX:412 338-7130 C A Pit WLG This law f irm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. ARD 31 SDSN6A01 0009249 AMY ORT -RAYMOND 321 4TH ST # B NEW CUMBERLND PA 17070-2120 payment cue ame August 30, 2005 - Address or telephone change? Please print change in the space above, , go to Discovercard.com. SAVE TODAY! Call 1-866-894-5727 to transfer your higher-rate balances to your Discover@) Card or visit Discovercard.com. J a i PO BOX 15251 WILMINGTON DE 19886-5251 000006011002730617685000000000000000064700 Discover Card Account Summary Closing Date: July 31, 2005 page 1 of 2 previous balance $3,700.00 account number 6011 0027 3061 7685 payments and credits - 3,700.00 payment due date August 30, 2005 purchases + 0.00 !tninimum payment due $647.00 cash advances + 0.00 ::redit limit $1,500.00 balance transfers + 0.00 credit available $-2,200.00 cash credit limit $800.00 FINANCE CHARGES + 0.00 ash credit available $0.00 new balance = $0.00 E"I'A"HIBIT tr Cashback Bonus® Cashback Bonus® Anniversary Date: March 25 Previous Cashback Bonus Award Balance $ 0.00 Purchase Award This Period + 0.00 Cashback Bonus Award Total 0.00 Redemptions This Period 0.00 Cashback Bonus Award Balance 0.00 Award Available to Redeem $ 0.00 Transactions trans. post date date Payments and Credits Jul 31 Jul 31 INTERNAL CHARGE-OFF $ -3,700.00 Nominal ANNUAL Transaction Average Daily Daily Periodic ANNUAL PERCENTAGE PERCENTAGE Periodic FINANCE Fee FINANCE Balances Rates RATES RATES CHARGES CHARGES current billing period: 6 days Purchases $0 0.03559% 12.99% F 12.99% $0 none Cash Advances $0 0.05751% 20.99% F 20.99% $0 $0 -•-- •??• ????., f, ,-. v Arrnunt are either fixed (F) or they may vary (V) as noted above. 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 Robert Adkins Accounts Manger of Discover Bank, Plaintiff herein, that he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief. Signature WWR# D qy? 9 0,5 ? n ? w' 4 J C_? 0 n ?, f L a -4 ?2 .. J x 17 r 1(/ CTI IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. AMY ORT-RAYMOND AKA AMY L ORT-RAYMOND Defendant No. 05-5050CIVIL PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOLCZAN, ESQUIRE PA I.D.947437 Wellman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04469059 Judgment Amount S 4,200.00 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. AMY ORT-RAYMOND AKA AMY L ORT-RAYMOND Defendant FO THE PROTHONOTARY: Civil Action No. 05-5050CIVIL PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, AMY ORT-RAYMOND AKA AMY L ORT-RAYMOND above named, in the default of an Answer, in the amount of $4,200.00 computed as follows: Amount claimed in Complaint $3,700.00 Interest from date of judgment at the legal interest rate of 6% per annum Attorney's fees $500.00 TOTAL $4,200.00 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: L t W ILLIAM T. MOLCZAN, FjhQU1RE JJ PA I.D.44743-, Welnnan, Weinberg & Reis Co., L.P.A- 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04469059 Plaintiff s address is: cio Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7" Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 321 4TH ST # B. NEW CUMBERLAND,PA 17070 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff 05-5050CIVIL AMY ORT-RAYMOND - AKA AMY RAYMOND Defendant IMPORTANT NOTICE TO: AMY ORT-RAYMOND - AKA 321 4TH ST # B NEW CUMBERLAND,PA 1 070 i Date of Notice: M/,'- C J 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 AC'T' 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 WELTMAN, WEI BERG & REIS CO., L.P.A. By: W William . Molczan, uire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #04469059 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. AMY ORT-RAYMOND AKA AMY L ORT-RAYMOND Case no: 05-5050CIVIL NON-MILITARY AFFIDAVIT Defendant The undersigned, who first being duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further 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, AMY ORT- RAYMOND AKA AMY L ORT-RAYMOND is not in the 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 Defendant, AMY ORT-RAYMOND AKA AMY L ORT-RAYMOND is not in the military service. Further Affiantsayeth naught. VI/ / ..? AFFIANT SWORN TO AND SUBSCRIBED in my presence this day of 1 }U ?3er• Vlndtt G t ?Ur N ARY PU IC _ 51y1tCxr""r, ci x- This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members' Civil Relief Act Page 1 of 1 NOV-04-2005 10:56:43 '11' Last Name First/Middle Begin Date Active Duty Status Service/Agency ORT-RAYMOND AMY Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, the above is the current status of the individual, per the Information provided, as to all branches of the Military. Robert J. Brandewie, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense 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 Department of Defense strongly supports the enforcement of the Service Members Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly 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 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 is on active duty, or is otherwise entitled to the protections of the SCRA, you are most strongly encouraged to contact us by phone at (703-696-6762). We will then conduct further research. Your failure to re-contact DMDC may cause provisions of the SCRA to be invoked against you. This response reflects current active duty status only. For historical information, please contact the military services SCRA point of contact. See: http://www.defenselink.mil/faq/pis/PC09SLDR.html. Report ID, IRHRSUXMH https://www.dmdc.osd.mil/scra/owa/scra.pre_Select 11/4/2005 1IJ w :z r.> IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 05-5050CIVIL AMY ORT-RAYMOND AKA AMY L OR'l -RAYMOND Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or udg ent was entered against you on 1111?10S (xx) Assumpsit Judgment in the amount of $4,200.00 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 ofTraffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary BY PROT ONOTARY EP Y) AMY ORT-RAYMOND 321 4TH S"T # B NEW CUMBERLAND.PA 17070 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7" Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. AMY ORT-RAYMOND Defendant PNC BANK, N.A., Garnishee, No. 05-5050 CIVIL PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04469059 Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. AMY ORT-RAYMOND Civil Action No. 05-5050 CIVIL '7.2/ -Y-9, Defendant -W /3 ,c)£cc) dc,;Ls4l ?r A9 /6G70 PNC IOSBAAN-)K N.A, nn Garnishee PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... 1. 2. 3. 4. directed to the Sheriff of Cumberland County: against Amy Ort-Raymond, Defendant against PNC Bank N.A., Garnishee Judgment Amount Less payments of Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): By: William T. Molczan, ?fiuire PA I.D. 447437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04469059 $ 4,200.00 t3AD, 60 $ 400.00 $ 104.74 $ 106.10 $ 4,010.84 WELTMAN, WEINBERG & REIS CO., L.P.A. °o (1 s 9 qj? C C p+c C ? ?` G ? r 3 c? C rr Q ?S WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-5050 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From AMY ORT-RAYMOND, 321 4T' ST. #B, NEW CUMBERLAND, PA 17070 (1) You are directed to levy upon the property of the defendant (s)and to sell . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of PNC BANK N.A., 105 NOBLE BOULEVARD, CARLISLE, PA 17013 GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the gamishee(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; (3) 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 $3,800.00 Interest $104.74 Atty's Comm % Atty Paid $124.10 Plaintiff Paid Date: MAY 5, 2006 L.L. $.50 Due Prothy $1.00 Other Costs $106.10 CURTIS R. LONG Prothonotary (Seal) By: Deputy REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412434-7955 Supreme Court ID No. 47437 SHERIFF'S RETURN - GARNISHEE CASE NO: 2005-05050 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND DISCOVER BANK VS ORT-RAYMOND AMY AKA AMY L ORT- And now MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0014:00 Hours, on the 9th day of May , 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named PLAINTIFF , ORT-RAYMOND AMY AKA AMY L ORT-RAYMOND in the hands, possession, or control of the within named Garnishee PNC BANK N.A. 105 NOBLE BLVD PA 17013 Cumberland County, Pennsylvania, by handing to VIOLA ROELKE (ASST BRANCH MANAGER) , personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to Her Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 .00 So answers : R. Thomas Kline' Sheriff of Cumberland County 05/11/2006 Sworn and subscribed to before me this /G day of 2e<?? A.D. Proth notar i By - ep y She iff SIRLIN GALLOGLY & LESSER, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 1529 Walnut Street, Suite 600 Philadelphia, PA 19102 (215) 864-9700 Attorney for Garnishee DISCOVER BANK COURT OF COMMON PLEAS COUNTY OF CUMBERLAND VS. AMY ORT-RAYMOND NO. 05-5050 and PNC BANK, NATIONAL ASSOCIATION, GARNISHEE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of PNC Bank, National Association, Garnishee, in the above-captioned matter. JON for Garnishee Date: ? ?! ?l ? 1 r SIRLIN GALLOGLY & LESSER, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 1529 Walnut Street, Suite 600 Philadelphia, PA 19102 (215) 864-9700 Attorney for Garnishee DISCOVER BANK vs. COURT OF COMMON PLEAS COUNTY OF CUMBERLAND AMY ORT-RAYMOND and : NO. 05-5050 PNC BANK, NATIONAL ASSOCIATION, GARNISHEE TO: COMMONWEALTH OF PENNSYLVANIA, Plaintiff 1. No. 2. Yes, an account titled Amy L. Raymond. The total sum of $608.13 has been restricted pursuant to this Writ. Pursuant to the terms and conditions of the deposit agreement between the bank and the depositor, the bank claims a priority lien in, and a right of set-off against the account consisting of $100.00 Legal Processing Charge, leaving a balance for execution purposes of $508.13. In addition, pursuant to 42 Pa.C.S.A. Section 2503, garnishee attorneys fees are authorized in an amount to be determined and 3. - 6. No. attached funds. JONSIRLIN Atto e for Garnishee Dated: SEP72 =2006 12:21 PNC GARN ACCTS SERVICES 412 762 6178 P.01 VERIFICATION The undersigned hereby verifies that I am an authorized representative of PNC Bank, N.A.; that the statements made in the foregoing Answers to interrogatories are true and correct to the best of my knowledgc, information and belief and that these statements are made subject to the penalties of 18Pa. C.S. s4904, relating; to unsworn falsification to authorities. RE: Discover Bank vs: Amy Ort-Raymond Nam Positio DATE: 49d, dGL'I Z -01 Lit-233946.1 n r-a ?, Q Mt IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. AMY ORT-RAYMOND Defendant PNC BANK, N.A. Garnishee No. 05-5050 CIVIL PRAECIPE FOR JUDGMENT AGAINST GARNISHEE FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOLCZAN, ESQUIRE PA I.D.447437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04469059 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 05-5050 CIVIL AMY ORT-RAYMOND Defendant PNC BANK, N.A. Garnishee PRAECIPE FOR JUDGMENT AGAINST GARNISHEE TO THE PROTHONOTARY: Kindly enter Judgment against the Garnishee, PNC BANK, N.A. , in the amount of $508.13, which is less than Defendant owes to Plaintiff and which amount Garnishee has admitted owing to the Defendant, in answers to Interrogatories. WELTMAN, WEINBERG & REIS CO., L.P.A. By: ' WILI,IA T. M LCD N, ESQUIRE PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04469059 I hereby certify that the address of the Plaintiff is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`" Avenue, Pittsburgh, PA 15219 And that the last known address of the Garnishee is: 105 NOBLE BLVD., CARLISLE, PA. 17013. Y SIRLIN GALLOGLY ez LESSER o PROF ESSKONA). CORPORATION AITQRNI:YS AT IlAW JON C. SIRLIN TIMOTHY A. GALLOGLY PETER A. LESSER* JOHN D. BENSON* SUSAN], KUPERSMITH• t DANA S.PLONO DOROTHY ANNE HAMILL LISA M. RUTENBERG ??• JERRY I, DREW-- KIERSTIN M. LSNCE+ • PA & NJ BAR • PA & NY BAR ^ PA, NJ, MV & VA RAA t C04 NS El. September 22, 2006 William Molczan Esquire 436 7th Avenue Suite 2718 Pittsburgh, PA 15219 Re: Discover Bank vs. Amy Ort-Raymond 811A PNC Rank, National Acsneiatinn, Ga_rni'.chep Dear Mr. Molcaaw PENNSYLVANLI OFFICE 1529 WALNUT STREET SUITE 600 PHILADELPHIA. PA 19102 (215) 864-9700 FAX (215) 864-9669 NEW JERSEY OFFICE 102 DROWNING LANE BUILDING C CHERRY HILL, NJ 08003 (856) 616•I900 FAX (856) 216.7459 Enclosed herein please find a copy of Garnishee's Answers to Interrogatories, which I am filing with the Prothonotary on behalf of PNC Bank, National Association in the above matter. Please note that PA R.C.P. No, 3123.1(c) prohibits Entry of Judgment against Garnishee until the expiration of twenty days from the date of service of the Writ of Execution upon garnishee, Please be advised that pursuant to 42 PA C.S.A. Section 2503, the Garnishee's fee and costs in the minimum amount of $300.00 will be deducted from Defendant's account at the time of Entry of Judgment. PLEASE DIRECT ANY INQUIRIES TO - (215) 864-970% EXT. 33. cerely ION C. SIRLIN alp Enclosure b00/Z001A 7$os R99Rb99C17 VV4 PC fii ?nn???aicr, r SIRLIN GALLOGLY & LESSER, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 1529 Walnut Street, Suite 600 Philadelphia, PA 19102 (215) 864-9700 Attorney for Garnishee DISCOVER BANK COURT OF COMMON PLEAS COUNTY OF CUMBERLAND vs. AMY ORT-RAYMOND and NO. 05-5050 PNC BANK, NATIONAL ASSOCIATION, CTARNISTIER TO: COMMONWEALTH OF PENNSYLVANIA, Plaintiff 1. No. 2. Yes, an account titled Amy L. Raymond. The total sum of $608.13 has been restricted pursuant to this Writ. Pursuant to the terms and conditions of the deposit agreement between the bank and the depositor, the bank claims a priority lien in, and a right of set-off against the account consisting of $100.00 Legal Processing Charge, leaving a balance for execution purposes of $508.13. In addition, pursuant to 42 Pa.C.S.A. Section 2503, garnishee attorneys fees are authorized in an amount to be determined and attached funds. 3.- 6. No. Dated, JONSIRLIN Atto a for Garnishee b00/600 1A IM 699GV989LZ XVd 89 bl 9002/ZZ/60 t SEP-22-2806 12:21 r PNC DARN ACCTS SERVICES YERT + CATION The undersigned hereby verifies that I am an authorized representative of PNC Bank, N.A.; that the statements made in the foregoing Answers to interrogatories are true and correct to the best of my knowledge, information and belief and that these statements are made subject to the penalties of I@Pa. C.S. s4904, relating; to amsworn fale fleation to authorities. REt Discover Bank vs: Amy Ort-Raymond DATE: a ?XJ6 Lit-233946.1 , //,/., 7, ? /, -?? "/, , , Namoo, POSWO b00/b00 2 I'Os 6990 983LZ XHA 89 bl 904Z/ZZ/60 r_-? c to Ci ?? L r W IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 05-5050 CIVIL AMY ORT-RAYMOND Defendant PNC BANK, N.A. Garnishee NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff ( ) Defendant (xx) Garnishee You are hereby notified that the following Order or Judgment was entered against you on (xx) Assumpsit Judgment in the amount of $508.13 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: c 105_ak"?& P OTHONOT ( DEPUTY) Pnc Bank, N.A. 105 Noble Blvd., Carlisle, Pa. 17013 SIRLIN GALLOGLY & LESSER, P.C By: Jon C. Sirlin, Esquire, I.D. No.: 17498 1529 Walnut Street, Suite 600 Philadelphia, PA 19102 (215) 864-9700 Attorney for Garnishee DISCOVER BANK COURT OF COMMON PLEAS COUNTY OF CUMBERLAND vs. : AMY ORT-RAYMOND : NO. 05-5050 and : PNC BANK, NATIONAL ASSOCIATION, GARNISHEE ATTORNEY I.D.#17498 BILL OF COSTS OF GARNISHEE, PNC BANK, NATIONAL ASSOCIATION Garnishee, PNC Bank, National Association, hereby bills the following costs to the fund attached, and will be satisfied therefrom as authorized by 42 Pa.C.S.A. Section 2503: Garnishee's fee pursuant to 42 Pa. C.S.A Section 2503: Notary Charges: Entry of Appearance: Answers to Interrogatories: Order to Discontinue or Satisfy: Other: 295.00 0.00 0.00 0.00 5.00 0.00 300.00 JON C. Garnishee Costs are hereby taxed in the amount of of 2006. BY: ?°' :.-? ?? t:.? -:-? c` ? _?, _ ?i ?? ?+ ..?- .. ' ?' _ -. ?^ 4? G IN THE COURT OF COMMON PLEAS OF CUMBERLAND CIVIL DIVISION DISCOVER BANK Plaintiff VS. AMY ORT-RAYMOND AKA AMY L ORT-RAYMOND Defendant PNC BANK Garnishee No.: 05-5050CIVIL PRAECIPE TO SET &ENDASTOTHE PNC BANK ONLY FILED ON BEHAL Plaintiff , PENNSYLVANIA TLE, DISCONTINUE GARNISHEE OF COUNSEL OF REQO THIS PARTY: James C. Warmbroot PA I.D #42524 WELTMAN, WEI B. 2718 Koppers Buil in 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04469059 OF & REIS CO., L.P.A. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. AMY ORT-RAYMOND AKA AMY L ORT-RAYMOND Defendant PNC BANK Garnishee i Civil Action No.: 0?-5050CIVIL TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue and End the above captioned matter ato Garnishee, PNC BANK, only, upon the records of the Court and mark the cost paid. W ELTMAN, By: Xy ? James C. W bro PA LD #4 2 WELTM N, EI1 2718 yKo pe Buil 436 Avent Pitts, PA 15-, (412 -7955 59 Sworn to and subscribe Before me the -?-' Day of NOVEMBER, 06 NO RY PUBLI Nlotetlal V*rwA.Jones, NoWyPd* 0FPItl bUMh,A1e"W0W* My ExOme June 29,2010 Member, Pennsylvania Association of Notaries & REIS CO., L.P.A. & REIS CO., L.P.A. n? 1 Q 61 vl C C= Q © -n Q. 7) [s:7 O rt f , s M23 l ' Z -? S ? Iy ? Cy - r? r d ? R. Thomas Kline, Sheriff,,pt0(efifg; fl` ,cording to law, states this Writ is returned ABANDONEb, no action taken in six months. Sheriff's Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pone Sale Certified Mail Postage Garnishee TOTAL 209b tl M -9 A !0: 53 18.00 1.68 .50 1.00 4.40 30.00 20.00 .78 9.00 85.36 Advance Costs: 150.00 Sheriff's Costs 85.36 64.64 Refunded to Atty on 03/21/07 So Ailswgp, R. Thomas Kline, Sheriff o PA. `=?T 3j.29/07 ? 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D #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04469059 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 05-5050CIVIL AMY ORT-RAYMOND Defendant PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WELTMAN, WEINBERG & REIS CO., L.P.A. By: JAMES C RMBRODT PA I. D #4 5 4 WELTM N, WEINBERG & REIS CO., L.P.A. 2718 pp rs Building 436 ve h Avenue Pitts ur , PA 15219 (41 ) 4-7955 WWR #04469059 Sworn to and subscribed before me this. day o arch, 08 N BLIC COMMONWEALTH OF PENNSYLVANIA Notarial Seal Jennifer M. Borowski, Notary Public City of Pittsburgh, Allegheny County My Commission Expires Feb. 22, 2012 Member, Pennsylvania Association of Notaries F ? X Q ?`! 0 '?"7.i? V - ?° `-- . ? C? -? ;, ...- ?y?, ,`?. _ .. _., ???: " :; i d, v/r