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HomeMy WebLinkAbout05-6672IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION I DISCOVER BANK Plaintiff vs. WILLIAM J DOYLE AKA WILLIAM DOYLE Defendant No: QS- "';L (2IUI COMPLAINT IN CIVIL ACTION 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 04833170 C A Pit WLG IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action. No WILLIAM J DOYLE AKA WILLIAM DOYLE 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: WILLIAM J DOYLE 38 S 38TH ST CAMP HILL, PA 17011 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011002070739123 . 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 December 09, 2005 , in the amount of $4106.62 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 , WILLIAM J DOYLE INDIVIDUALLY , in the amount of $4106.62 with interest at the legal rate of 6.000 per annum from date of judgment plus attorneys' fees of $500.00 , and costs. I = WELT , W:EINBERG &REIS CO., L.P.A. 436 Se enth Avenue, Suite 2718 Pittsb rgh, PA 15219 (412) 434-7955 FAX: 412-3:38-7130 04 3170 C A Pit WLG 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. 1161#11.7%3%.0 V GR $0.00 CARD $766.00 i J enter amount enclosed below payment due date $ November 29, 2005 31 SDSN6A01 0005944 WILLIAM DOYLE 38 5 38TH ST CAMP HILL PA 17011-4307 Address or telephone change? Please print change in the space above, or go to Discovercard.com. To order Cash Access Checks, select your P.I.N., or to find cash locations call 1-800-DISCOVER (1-800-347-2683) or visit Discovercard.com. PO BOX 15251 11111111 11111 if r r r III r 11111 WILMINGTON DE 19886-5251 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 1 i 1,11„ III, [sit tilI I I I , I'll I I I 1I 11 000006011002070739123000000000000000076600 Discover Card Account Summary account number 6011 0020 7073 9123 payment due date November 29, 2005 minimum payment due $766.00 credit limit $3,600.00 credit available $-506.00 cash credit limit $1,800.00 cash credit available $0.00 Closing Date: October 31, 2005 page 1 of 1 previous balance $4,106.62 payments and credits - 4,106.62 purchases + 0.00 cash advances + 0.00 balance transfers FINANCE CHARGES new balance + 0.00 + 0.00 an nn EXHIB11 - -A_.. Cashback Bonus' Cashback Bonus® Anniversary Date: October 6 Opening Cashback Bonus Balance New Cashback Bonus Earned Cashback Bonus Balance Available to Redeem $ 0.00 + O.DD $ 0.00 $ 0.00 Transactions trans, post date date Payments and Credits Oct 31 Oct 31 INTERNAL CHARGE-OFF $ -4,106.62 Nominal Average Daily ANNUAL ANNUAL Periodic Transaction Fee Daily Periodic PERCENTAGE PERCENTAGE FINANCE FINANCE Balances Rates RATES RATES CHARGES CHARGES current billing period: 25 days Purchases $0 0.07326% 26.74% V 26,74% $0 none Cash Advances $0 0.07326% 26.74% V 26.74% $0 $0 The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above. Questions? Call 1-600-DISCOVER (1-600-347.2683) or log on to Discovercard.com. For TDD ate'' a (Telecommunication Device for the DeaQ assistance, call 1-800-347-7449. Send billing error notice to: DISCOVER 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#uL I? %P ? t ? ? >' n c r ? r t? \ - rx \ rnf" r_r .;,d? ? \ - -7 . ( ` `f-ti J SHERIFF'S RETURN - REGULAR CASE NO: 2005-06672 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS DOYLE WILLIAM J AKA WILLIAM DO SHANNON SHERTZER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE DOYLE WILLIAM J DEFENDANT A WILLIAM DOYLE was served upon the , at 1840:00 HOURS, on the 29th day of December , 2005 at 38 S 38TH STREET CAMP HILL, PA 17011 WILLIAM DOYLE by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs Docketing 18.00 Service 13.44 Affidavit .00 Surcharge 10.00 .00 41.44 Sworn and Subscribed to before me this day of ?vvG A.D. Pr notar? So Answers: R. Thomas Kline 12/30/2005 WELTMAN WEINBERG REIS By: eputy Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUN'LY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. WILLIAM J. DOYLE AKA WILLIAM DOYLE Defendant No. 05-6672 CIVIL TERM PRAF:CIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM "I . MOLCLAN, ESQUIRE PA I.U.#47437 Weltman, Weinberu & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412).434-7955 W W R4'04833170 Judgment Amount $ 4,606.32 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. Civil Action No. 05-6672 CIVIL TERM WILLIAM J. DOYL.EAKA WILLIAM DOYLE Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendants, WILLIAM J. DOYLE AKA WILLIAM DOYLE above named, in the default of an Answer, in the amount of $4,606.32 computed as follows: Amount claimed in Complaint $4,106.32 Interest from date of judgment at the legal interest rate of 6% per annum Attorney's fees $500.00 IOTA L $4.606.32 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. WF.LTMAN, WEINBERG & REIS CO., L.P.A. By: WILLIAM T. MOLCZAN, -SQUIRE PA I.D.447437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W W R#04833170 Plaintiffs address 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 Defendants is: 38 S. 38`x' Street, Camp Hill, PA 17011 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL. DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 05-6672 CIVIL TERM WILLIAM J. DOYL,E AKA WILLIAM DOYLE Defendant NOTICE OF JUDGMENTORORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order ??orrr?? ?Judgment was entered against you on _.[ Z_ -cjx_ I q, a.bdtp (xx) Assumpsit Judgment in the amount of $4,60632 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 o'f Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary/ BY S?.......L.?2%G ? r.../.... _ PR(1TIIONOTARY m,: DL; ; ";- J L William J. Doyle 38 S. 38'" Street Camp Hill, PA 17011 Plaintiffs address is: c/o Weltman, Weinberg K Reis Co., L.P.A., 2718 Koppers Building, 436 7"' Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff WILLIAM J DOYLE Defendant(s) IMPORTANT NOTICE TO: WILLIAM J DOYLE 38 S 38TH ST CAMP HILL,PA 17011 /! Date of Notice: ()?/ G, 4Qb WWR#: 04833170 yj ( \? Case # (-V- 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 FOLLOWING 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. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 BY: JAMES WAR RODT, ESQUIRE PA I.D. 4 524 WELTMAN, INBERG & REIS CO., L.P.A. 2718 KO P RS BLDG, 436 7TH AVE. PITTSB dW.H, PA 15219 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. WILLIAM J. DOYLE AKA WILLIAM DOYL.E Case no: 05-6672 CIVIL TERM 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, WILLIAM J. DOYLE AKA WILLIAM DOYLE is not in the military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMD('), which states that the Defendant, WILLIAM J. DOYLE AKA WILLIAM DOYL.,E is not in the military service. Further Affiant sayeth naught. AFFIANT SWORN AND SUBSCRIBED in my presence this ID day of OTARY PUBLIC 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 I of I MAR-09-2006 07:44:03 Last Name First/Middle Begin Date Active Duty Status Service/Agency DOYLE WILLIAM J 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.htmi. WARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: USLCKPICGZ hups://www.dmdc.osd.mil/scra/owa/scra.prc_Select 3/9/2006 -,0 ( V ? ely &. - i t * .6b. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. WILLIAM J DOYLE AKA WILLIAM DOYLE Defendant PENNA STATE EMPLOYEES CU, Garnishee, - AIK 1A 3 8, S 3g 6 sft-eeT' CA f -« 1 70/ ! No. 05-6672 CIVIL TERM 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 W W R#04833170 p6-roqR stJe E-MployePs j Crept it UA,`.9n P1 PAf P 1) b P,4. 17110 C1) , r A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. WILLIAM J DOYLE, AKA WILLIAM DOYLE Defendant PENNA STATE EMPLOYEES CU. Garnishee Civil Action No. 05-6672 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION TO Tf IE PROTHONOTARY: Kindly isle a Writ of Execution in the above matter... 1. directed to the Sheriff of Dauphin County: 2. against William J. Doyle, Defendant 3. against Pemta State Employees CU, Garnishee 4. Judgment Amount Interest C.)sts SUBTOTAL: Costs (to be added by Prothonotary): $ 4,606.32 $ 108.29 $ $ 4,714.61 WELTMAN, WEINBERG & REIS CO., L.P.A. By: William . Moleza , Esqu' PA I.D. 447437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W W R#04833170 a- t ,4A 2v %-- w 0 ' 4 O' ? Dz) C) -7 -7 J WRIT OF EXECUTION and/or ATTACHMENT f , COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) TO THE SHERIFF OF DAUPHIN COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From WILLIAM J. DOYLE AKA WILLIAM DOYLE, 38 S. 38TH STREET, CAMP HILL, PA 17011 (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 PENNA STATE EMPLOYEES CU, 1 CREDIT UNION PL., HARRISBURG, PA 17110 GARNISHEE(S) as follows: and to notify the gamishee(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; (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 $4,606.32 Interest $108.29 Atty's Comm % Atty Paid $114.94 Plaintiff Paid Date: AUGUST 28, 2006 (Seal) L.L. $.50 Due Prothy $1.00 Other Costs URTIS R.' ONG Prothonotary By: NO 05-6672 Civil CIVIL ACTION - LAW 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: 412-434-7955 Supreme Court ID No. 47437 IiJ "1'1-IE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION? DISCOVER BANK Plaintiff vs. WILLIAM J DOYLE AKA WILLIAM DOYLE Dei;:n,Jam and PENNA STATE EMPLOYEES CU Garni?hcc auop ?JT u35c? No. 05-6672 CIVIL TERM AK5u,?ef'5 7b INTERROGATORIES IN ATTACHMENT PENNA STATE EMPLOYEES CU FILED ON BEHALF OF: Plaintiff rv N COUNSEL OF RECORD OF Tl-IIS PARTY: William T. Molczan, Esquire PA J.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W W R#04833170 Q3 ?Z ?E 6 t Z J3S Sfl IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vE. WILLIAM I DOl LF, AKA WILLIAM DOYLE Defendant and PENNA STATE EMPLOYEES CU Garnishee c? r? -17 N TO: PENNA STATE EMPLOYEES CU Suggested Reference No.: XXX-XX-4830 I CIZE.DIT UNION PL, RE: WILLIAM J DOYLE - AKA I-IAIZRISIMRG, PA 17110 38 S 38TI-I ST., CAMP HILL,PA 17011 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. 13. I-lerein, the word "defendant" means any one or more of the defendants against whom the writ of Execution i,, issued. C. Vl'hile 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. aww MT 455(p Civil Action No.: 05-6672 CIVIL TERM 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? No. 2. 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 3. 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. 4. If the answer to Interrogatory 3 is in the affirmative, describe the nature, fair market value, and present location of each of such properties. Account #0169644830 William J. Doyle S1 Regular Shares $ 9.01* S4 Checking $1,697.30 *$5.00 Membership Fee held in Regular Shares. 5. 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. 6 . If the a:-iswer to Interrogatory 5 is in the affirmative, describe the nature, fair market value, and present location of each of said properties. N/A 7. 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. 8. If the answer to Interrogatory 7 is in the affirmative, describe the nature, fair market value, and present location oi'each of such properties. N/A 9. 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. 10. If the answer to Interrogatory 9 is in the affirmative, describe the nature, fair market value, and present location oi' each of such properties. N/A 11. 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. 12. If the answer to Interrogatory I l is in the affirmative, describe the amount or nature, fair market value and present location of each of such payments and properties. N/A WELTMAN, WEINBERG & REIS CO., L.P.A. By: - k/1 William T. Molczan, Esqu' PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W W R#04833 l 70 C ? G ' AG , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. No.: 05-6672 CIVIL TERM PRAECI:PE TO SETTLE, DISCONTINUE & END AS TO THE GARNISHEE PENNA STATE EMPLOYEES CREDIT UNION ONLY WILLIAM J DOYLE AKA WILLIAM DOYLE Defendant PENNA STATE EMPLOYEES CREDIT UNION Garnishee FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA I.D #42524 WELTMAN WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 1521.9 (412) 434-7955 WWR#04833170 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. WILLIAM J DOYLE AKA WILLIAM DOYLE Defendant PENNA STATE EMPLOYEES CREDIT UNION Garnishee Civil Action No.: 05-6672 CIVIL TERM PRAECIPE TO SETTLE DISCONTINUE AND END AS TO THE GARNISHEE, PENNNA STATE EMPLOYEES CREDIT UNION, ONLY TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue and End the above captioned matter as to Garnishee, PENNA STATE EMPLOYEES CREDIT UNION, only, upon the records of the Court and mark the cost paid. WELTMAN, WEINJOERG & REIS CO., L.P.A. Y 1 r r By: James C. W, ar brodt PA LD #4'.524 WELTMAN, INBERG & REIS CO., L.P.A. 2718 Koppers uilding 436 Seventh enue Pittsburgh, A 15219 (41.2)434 955 WWR#04833170 Sworn to and subscribed 0? of 2006 Before tY' tVION EALTH Of: PENNSYLVANIA TA3r ? ?:'l7 10 0 e 67- f , - of Mary Jane Snyder Real Estate Deputy William T. Tully Solicitor Office of t4e ?4-erfff Charles E. Sheaffer Chief Deputy Michael W. Rinehart Assistant Chief Deputy 0 qj*"3 _? 17 D Dauphin County Harrisburg, Pennsylvania 17101 ph: (717) 255-2660 fax: (717) 255-2889 J.R. Lotwick Sheriff October 18, 2006 IN THE COURT OF COMMON PLEAS OF DAUPHIN COUNTY Discover Bank VS William JDoyle a/kla William Doyle TO THE SHERIFF: CIVIL ACTION EXECUTION NO. 4356 NT 2006 FILE NO. FORMAL REQUEST TO STAY WRIT OF EXECUTION Return the within-captioned Writ of Execution for the following reasons: ? STAYED ? ABANDONED ? EXPIRED ? NOT FOUND Debtor(s) made a E:] Partial ? Full Payment of $ or their Attorney. 71- directly to Plaintiff(s), The aforesaid payment is allocated as follows: Debt ........................................................... $ Interest ....................................................... $ O.C.P.P & This Writ ................................. $ Attorney Commissions .............................. $ Other $ Dated Attorney for Plaintiff(s) Note: Please return this form within 30 days - if not returned, the Sheriffs Office will assume that you have been paid in full and charge 2% Poundage plus Costs. SHERIFF'S RETURN 4356-NT - - -2006 PERSONAL PROPERTY WRIT OF EXECUTION & INTERROGATORIES DISCOVER BANK vs DOYLE WILLIAM J A/K/A DOYLE WILLIAM And Now: September 21, 2006 at 3:23 P.M. RECEIVED FROM PROTHONOTARY - PP And Now: October 9, 2006 at 10:55 A.M. PAYMENT RECEIVED Receipt # 222253 And Now: October 9, 2006 at 2:12 P.M. INITIAL SERVICE And Now: October 16, 2006 at 12:25 P.M. SERVED GARNISHEE(S) And Now: October 16, 2006 at 12:25 P.M. AS COMMANDED DID ATTACH ALL MONIES,DEBTS, CREDITS, RIGHTS, INTEREST, REAL & PERSONAL PROPERTY OF WILLIAM J DOYLE A/K/A WILLIAM DOYLE DEFT IN HANDS OF PSECU GAR BY HANDING TO HARRY SMITH COLL MGR A COPY OF WRIT/INTERROGATORIES AND MAKING KNOWN TO HIM AT ONE CREDIT UNION PLACE, HARRISBURG, PA. ALSO LEFT WITH GARNISHEE A LIKE COPY OF WITHIN WRIT FOR WITHIN NAMED DEFT. DC Sheriff's Costs So Answers, State/Prothonotary Fee Poundage e ,f* ~+ , J. R. Lotwick, Sheriff LO/18/2006 PAGE 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 05-6672-CIVIL TERM VS. PRAECIPE FOR WRIT OF EXECUTION WILLIAM J DOYLE (BANK ATTACHMENT ONLY) Defendant PENNSYLVANIA STATE EMPLOYEES CREDIT UNION M&T BANK, Garnishees, 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#4833170 3 ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK 6500 New Albany Road New Albany, OH 43054 Plaintiff vs. WILLIAM J DOYLE 38S38THST CAMP HILL,PA 17011 Defendant Civil Action No. 05-6672-CIVIL TERM PENNSYLVANIA STATE EMPLOYEES CREDIT UNION Third & Walnut St Harrisburg, PA 17110 M&T BANK 213 Market St Harrisburg, PA 17101 Garnishees PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of DAUPHIN County: 2. against WILLIAM J DOYLE, Defendant 3. against Pennsylvania State Employees Credit Union and M&T Bank, Garnishees 4. Judgment Amount $ 4,606.32 Less payments of $ 1,701.31 Interest $ 547.26 Costs $ SUBTOTAL: $ 3,452.27 Costs (to be added by Prothonotary): $ WELTMAN, EINBERG & REIS CO., L.P.A. By: William T. Molczan, quire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#4833170 ?. o cA CA . ?V. o h 000©-Gp ? ' ? .? ?s ; -.. 'T7 ,'-? -• i ,fie.. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-6672 Civil CIVIL ACTION - LAW TO THE SHERIFF OF DAUPHIN COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From WILLIAM J. DOYLE, 38 S. 38th Street, Camp Hill, PA 17011 (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 GARNISHEE(S) as follows: PENNSYLVANIA STATE EMPLOYEES CREDIT UNION, Third & Walnut Street, Harrisburg, PA 17110 M&T BANK, 213 Market Street, Harrisburg, PA 17101 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; (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 $2,905.01 Interest -- $$547.26 Atty's Comm % Atty Paid $150.94 Plaintiff Paid Date: 10/20/08 (Seal) L.L. Due Prothy $2.00 Other Costs Curtig'R. Long, Pr ary By: Deputy REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., LPA 2718 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 47437 I I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. WILLIAM J DOYLE Defendant and aco8'cV iq-4&s1wr No. 05-6672-CIVIL TERM A,?rLA-w s 4a INTERROGATORIES IN ATTACHMENT Pennsylvania State Employee Credit Union M&T Bank PENNSYLVANIA STATE EMPLOYEES CREDIT UNION M&T BANK Garnishees FILED ON BEHALF OF: Plaintiff N 7 "I't c-, 3t C3 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#4833170 r C77) r_:j 1 tJ..' . A IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. WILLIAM J DOYLE Defendant and 4004 C ? A16106 Alr Civil Action No.: 05-6672-CIVIL TERM h1 c? o c. -G N PENNSYLVANIA STATE EMPLOYEES CREDIT UNION M&T BANK Garnishees TO: Pennsylvania State Employees Credit Union Third & Walnut Streets Harrisburg, PA 17110 M&T Bank 213 Market Street Harrisburg, PA 17101 Suggested Reference No.: XXX-XX-4830 RE: WILLIAM J DOYLE 38 SOUTH 38TH ST CAMP HILL,PA 17011 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. . if 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 fto t ®Lcnd him any money or were liable to him for any reason? VV C Account balance under $, °D _ At a Negative Balance. Ia. 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. Z'Oo n o ff, , ( .,,, is -0 2. At the time you were served or at any subsequent time was the m of r pos ession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant. NO 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? kD 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? f Vu 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? 1\j 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 entity electronically depositing those funds on a recurring basis. 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 I exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. g 8123? If so, identify each account. NO WELTMAN, WEINBERG & REIS CO., L.P.A. 0gp K By: William T. Molczan, Es ire PA I.D. #47437 ??'' WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#4833170 1160 ?0 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 (Title) (Name) of , 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. (SIGNATURE) r-? p ?? ?Z'! ?, C°rv-3 4 ?' .-? . . _. ... :,y., i ;i? ?= ??? . ? r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA i EVIL DIVISION DISCOVER BANK Plaintiff No. 05-6672-CIVIL, TERM vs. 1'RF.r CIPt=,'i'O SETTL,E, DISCONTINUE & END AS "TO THE GARNISHEES PSECU AND M&T BANK ONLY WILL.IAN1.1 DOYLE Defendant PSEC[; M&T LANK Garnishees FILED ON BEHALF OF Plaintiff COUNSEL. OF RECORD OF THIS PARTY: William T. Molezan, Esquire PA I.D #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436,Seventh Avenue Pittsburgh, PA 15219 (412) 434-;'c,55 , W W R 4833170 i IN THE COURT OF COMMON PI F'AS CUMBERLAND COUNTY, PENNSYLVANIA ti::IVIL DIVISION DISCOVER BANK Plaintiff vs. WILLIAM J DOYLE Defendant PSECU M&"f - ANK Garnishees Civil Action No. 05-6672-CIVIL TERM PRAECIPE TO 5I -TTLE DISCONTINUE AND END AS TO THE CARNISIII?ES , FSECU AND IdI&z'T BANK, ONLY TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue and End the above captioned matter as to Garnishees, PSECU AND M&cT BANK, only, upon the records Jthe Court and mark the cost paid, WELTMAN, WEINBERG & REIS CO., L.P.A. B. ( y./! U) yy William Imo. Molcza , Esquire PA LD #4 743 7 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7-)55 WWR#4833170 Sworn to and subscribed Before me the 2,0 Day of NOVEMBER, ?2F 8 WayneA FV Public N(" ARY PU I. - - city of Pittsbur, Iy County My commis , _ :une 28, 2010 Member, Pennsyivani .'.,;u? ation of Notaries 00 -a -.s