HomeMy WebLinkAbout06-1774
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS.
PATRICIA SMITH
Defendant
No : dL - I77y
c?«U
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
05067858 C A Pit WLG
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action NoQ(o _ ?'77y 0,,`/
PATRICIA SMITH / h
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
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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:
PATRICIA SMITH
36 DREXEL PL
NEW CUMBERLND, PA 17070
3. Defendant applied for and received a credit card issued by
Plaintiff bearing the account number 6011002370104663 . 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 March 16, 2006 , in the amount of
$2445.04
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 $300.00
t
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 , PATRICIA SMITH INDIVIDUALLY , in the amount of
$2445.04 with interest at the legal rate of 6.000% per annum from date
of judgment plus attorneys' fees of $300.00 , and costs.
James /T, Warm t,4 24
WELTD , WEINBERG & REIS CO., L.P.A.
436 eventh Avenue, Suite 2718
Pit s urgh, PA 15219
(4 2) 434-7955
F 412-338-7130
7858 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.
payment due date $
February 27, 2006
31 SDSN6A01 0006776
PATRICIA SMITH
36 DREXEL PL
NEW CUMBERLND PA 17070-2202
Address or telephone change? Please print change in the space above,
orgo to Discovercard.com.
Use your card with confidence--Discover
Card ranked #1 in Fraud Protection Services
among the largest card issuers by Javelin
Strategy & Research in its 2005 report.
PO BOX 15251 IIIrr r 1111111 11 111111 111111
WILMINGTON DE 19886-5251
Inr1161111n66r11116u1r1ur1r1rIJrur11rl11111, lrlrJ
000006011002370104663000000000000000042400
Discover Card Account Summary -- - ------
Closing Date: January 31, 2006 --------
page 1 of 1
previous balance $2,445.04
account number 6011 0023 7010 4663 payments and credits - 2,445.04
payment due date February 27, 2006 purchases + 0.00
minimum payment due $424.00 cash advances + 0.00
credit limit $1,200.00
balance transfers
+ 0.00
credit available $-1,245.00
cash credit limit $600.00 FINANCE CHARGES + 0.00
cash credit available $0.00 new balance = $0.00
EXHIBIT
u nu
Cashback Bonus®
Cashback Bonus® Anniversary
Date: October 18
Opening Cashback Bonus Balance
New Cashback Bonus Earned
Cashback Bonus Balance
Available to Redeem
$ 0.00
+ 0.00
$ 0.00
$ 0.00
Transactions
trans. post
date date
'.Payments and Credits Jan 31 Jan 31 INTERNAL CHARGE-OFF $ -2,445.04
Nominal
ANNUAL Transaction
Average Daily ANNUAL Periodic Fee
Daily Periodic PERCENTAGE PERCENTAGE FINANCE FINANCE
Balances Rates RATES RATES CHARGES CHARGES
current billing period: 13 days
Purchases $0 0.06025% 21.99% V 21.99% $0 none
Cash Advances $0 0.06025% 21.99% V 21.99% $0 $0
The rates that apply to your Account 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 :&1q'eVL 46U111t5
(Name)
lq(fWtl A 6 ?t?nq gy of Discover Financial Services LLC , plaintiff herein, that
(Title) ' (Company)
he/she is duty authorized to make this Verification, and that the facts set forth in the foregoing Complaint
in Civil Action are true and correct to the best of his/her knowledge, information and belief.
(Signature)
WWR 4 5067858
PATRICIA SMITH
6011002370104663
.
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IN TFIF.. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
PATRICIA SMITH
Defendant
No.06-1774 CIVIL TERM
PRAECIPE FOR ENTRY OF
JUDGMENT BY CONSENT
FILED ON BEI ]ALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
Benjamin R. Bibles, Esquire
PA I.D. # X135_tJ
WELTMAN. WETN13FRG & REIS CO., L.P..A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
W W R#05067858
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintif'f'
vs.
PATRICIA SMITH
Defendant
Civil Action No. 06-1774 CIVIL TERM
PRAECIPE FOR JUDGMENT BY CONSENT
TO THE, PROTHONOTARY:
Kindly enter Judgment against Defendant, Patricia Smith, in the amount of $2,745.04 plus costs, based upon the
consent of the parties.
CONSENTED FO:
WELTMAN, WEINBERG & REIS CO., L.P.A.,
By 2z
:
Attor 7y?.Plaintff
PATRICIA SMITH,
By: PCB{" ?-,L
Defendant
WWR#05067858
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No. 06-1774 CIVIL TERM
PATRICIA SMITH
Defendant
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the following
Order or Judgment was entered against you
on -4-Al( polo
(xx) Assuntpsit Judgment in the amount
of $2,745.04 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
(XX) By Consent
Prothonotary
PATRICIA SMITH
36 DREXEL PL
NEW CIJMBERLND,PA 17070
By:
PROTHONOTARY (OR DEPUTY)
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-01774 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DISCOVER BANK
VS
SMITH PATRICIA
DAVID MCKINNEY
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
SMITH PATRICIA the
DEFENDANT at 1700:00 HOURS, on the 28th day of March , 2006
at 36 DREXEL PLACE
NEW CUMBERLAND, PA 17070 by handing to
PATRICIA SMITH
a true and attested copy of COMPLAINT & NOTICE together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
14.08 .00
10.00 R. Thomas Kline
.00
42.0 03/29/2006
WELTMAN WEINBERG REIS
Sworn and Subscribed to before
me this /q z day of
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By, y?
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'Deputy Sheriff
Prothonotary
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
PATRICIA SMITH
Defendant
PSECU,
Garnishee,
No. 06-1774 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
WWR405067858
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No. 06-1774 CIVIL TERM
PATRICIA SMITH
Defendant
PSECU,
Garnishee
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 Patricia Smith, Defendant
3. against PSECU, Garnishee
4. Judgment Amount $ 2,745.04
Less payments of -(1,000.00)
Interest $ 52.14
Costs $
SUBTOTAL: $ 1,797.18
Costs (to be added by Prothonotary): $
WELTMAN, WEINBERG & REIS CO., L.P.A.
B
Y•
William T. Molczan squire
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#05067858
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-1774 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s)
From PATRICIA SMITH, 36 DREXEL PL., 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 PSECU, 1 CREDIT UNION PL., HARRISBURG, PA 17110 -GARNISHEE
GARNISHEE(S) as follows:
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 $1,745.04
Interest $52.14
Atty's Comm %
Arty Paid $124.58
Plaintiff Paid
Date: OCTOBER 5, 2006
(Seal)
L.L. $.50
Due Prothy $1.00
Other Costs
Cu 4'sR.on thono ry
By:
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
Deputy
Supreme Court ID No. 47437
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
OPOOto - CV
Plaintiff No. 06-1774 CIVIL TERM
vs. n5? INTERROGATORIES IN ATTACHMENT
PSECU
PATRICIA SMITH t-0
Defendant
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and cri
PSECU `
.w. N
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 Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
1
WWR#05067858 v? "
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IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No.: 06-1774 CIVIL TERM
PATRICIA SMITH
Defendant
and
PSECU
Garnishee
TO: PSECU Suggested Reference No.: XXX-XX-2499
1 CREDIT UNION PL., RE: PATRICIA SMITH
HARRISBURG, PA 17110 36 DREXEL PL.,
NEW CUMBERLAND,PA 17070
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.
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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.
S1 Regular Shares $ 1.22*
S4 Checking $1,050.15
*$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 answer 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.
Ab.
8. If the answer to Interrogatory 7 is in the affirmative, describe the nature, fair market value, and
present location of 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 of 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 11 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:
William . Molc , 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#05067858
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS.
PATRICIA SMITH
Defendant
PSECU
Garnishee
No. 06-1774 Civil Term
PRAECIPE FOR JUDGMENT AGAINST
GARNISHEE
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 Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#05067858
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No. 06-1774 Civil Term
PATRICIA SMITH
Defendant
PSECU
Garnishee
PRAECIPE FOR JUDGMENT AGAINST GARNISHEE
TO THE PROTHONOTARY:
Kindly enter Judgment against the Garnishee, PSECU , in the amount of $1,046.37, 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: " r
L-- -
WILLIAM T. MOhCZV, ESQUIRE
PA I.D.#47437 (V
Weltman, Weinberg & Reis Co., L.P.A.
2718 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#05067858
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: P.O. Box 67013, Harrisburg, PA 17106
t
NCV, 21. 2^S6 1:45PM PSECU
PSECU
Facsimile Transmittal
Date: November 27, 2006
N^. 051' P. 1
To: William T. Molczan, Esquire
Fax #: 412-338-7130
Location: WELTMAN, WEINBERG & REIS CO., L.P.A.
From: Pennsylvania State Employees Credit Union
Kathleen Weinstein
PSECU FAX#: 717-772-2273
Re: WRIT Interrogatories - Discover Bank vs Patricia Smith
WWR# 05067858
Number of pages immediately following transmittal: 5
If you have not received a clear facsimile transmittal or if you
have not received all required pages, please contact sender at
800-237-7328 Menu 6, Ext 3117
NOV.27. 2006 1.45PN PH U
IPsECO
William T. Molczan, Esquire
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
PAX # 412-338-7130
Re: Discover Bank
v. Patricia Smith
Dear Mr. Molczan:
No. 0571 P. 2
November 27, 2006
This letter follows our receipt of a writ of attachment from your office on our member(s)
Patricia Smith- We attached funds in the amount of $1,046.37. This amount excludes a
$5.00 membership fee in Regular Shares.
Enclosed are the answered interrogatories. Please let us know if you wisp: to garnish the
funds or dissolve the attachment.
Should you have any questions, you may contact me at (800) 237-7328, menu selection
46, extension 3117.
Sincerely,
Enclosure
Kathleen Weinstein
Account Advisor
f
Pennsylvania State Empl7ees Credit Union
Main Address: 1 Credit Union Place, Harrisburg, PA 17110-2990 - 717.234.8484 - 800.237.7328
Mailing Address: P.O. Box 67013, Harrisburg, PA 17106-7013 - 71.7_._7.77.2100 (TDD) - 800.472.1967 (M)_ _
is federally Insured by the Nolienei Credo Union AdminLNrelien. Equal Opporlunly lender VAAM.psecu.com
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NOV, 27. 2PC6 ' :45'M PSECU N0, n) 571 P, 3
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff ,
V5.
PATRICIA SMITH
Defendant
and
PSECU
Garnishee
vZ00(0 - Cl, 5?Q1
No. 06-1774 CIVIL TERM
INTERROGATORIES IN ATTACHMENT
PSECU
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FILED ON BEHALF OF: ---
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan, Esquire
PA I.D. #47437
WEINBERG & REIS CO., L.P.A.
WELTMAN
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2718 Koppers Building
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43 6 Seventh Avenue y 4.
Pittsburgh, PA 15219
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(412) 434-7955 N
W'W'R#05067858
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NCV, 27. 2006 1; 45PM PSEC U NO, "057' P, 4
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No.: 06-1774 CIVIL TERM
PATRICIA SMITH
Defendant
and
PSECU
Garnishee
TO: PSECU Suggested Reference No.: XXX-XX-2499
1 CREDIT UNION PL., RE: PATRICIA SMITH
HARRISBURG, PA 17110 36 DREXEL PL.,
NEW CUMBERLAND,PA 17070
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. Whale 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 Gamishee-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.
N^v, 27. 2?0 45°M PSECU N^, X57? P,
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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.
S1 Regular Shares $ 1.22*
S4 Checking $1,050.15
*$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 answer 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.
NCV, 27. 2006 1:45'm
PSEC U NO. 057' P. 6
8. If the answer to Interrogatory 7 is in the affirmative, describe the nature, fair market value, and
present location of 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 of 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 1 is in the affirmative, describe the amount or nature,
fair market value and present location of each of such payments and properties.
N/A
WBLTMAN, WEINBERG & REIS CO., L.P.A.
By:
William. Molcza Es e
PA I.D. #47437
WELTMAN, WEINBBRG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#05067858
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N - ? ?!es
1
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS.
PATRICIA SMITH
Defendant
PSECU
Garnishee
Civil Action No. 06-1774 Civil Term
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
( ) Defendant
(xx) Garnishee
You are hereby notified that the
following Order or Jud nt was
entered against you on !19-r- AOG6
(xx) Assumpsit Judgment in the amount
of $1,046.37 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
Psecu
Kathleen Weinstein
P.O. Box 67013
Harrisburg, Pa 17106
Prothonotary
/ /./, 4 4, 41.. d
By:
P OTHO R I (18q+ )
44%
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISOVER BANK
Plaintiff
VS.
PATRICIA SMITH
Defendants
PSECU
Garnishee
No.: 06-1774 CIVIL TERM
PRAECIPE FOR SATISFACTION OF
JUDGMENT AS TO THE GARNISHEE
PSECU ONLY
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
James C. Warmbrodt
PA I.D #42524
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 No. 05067858
f
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISOVER BANK
Plaintiff
vs.
PATRICIA SMITH
Defendants
PSECU
Garnishee
Civil Action No.: 06-1774 CIVIL TERM
PRAECIPE FOR SATISFACTION OF JUDGMENT
AS TO THE GARNISHEE, PSECU, ONLY
TO THE PROTHONOTARY:
Please kindly Satisfy the Judgment of the above captioned matter upon the records of the Court and
mark the cost paid as to Garnishee, PSECU, only.
Sworn to and subscribed
Before e the
Day f BRUAR 2007
QTARY BLIC
WELTMAN, WEINBERG & REIS CO., L.P.A.
Esquire
& REIS CO., L.P.A.
2718 Kopper/Building
436 Sevz
avenue
Pittsburg A 15219
(412)43 55
By
:
James C. W
PA LD #42 2,
William T,. M(
PA. I.D.#4743
WELTMAN, '
Notarial Seat
Wendy L. Gauft, Notary Public
ty 0r pibbutgh, AII9.lelly y
p0mmtsgj07} r-xp+resJy *15,2010
,? pp yivane Assoaat!nn of NO"
i
W WR No. 05067858
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MC FEB -2
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
PATRICIA SMITH
Defendant(s)
No. 06-1774 CIVIL TERM
PRAECIPE FOR SATISFACTION OF
JUDGMENT
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
James C. Warmbrodt, Esquire
PA I.D. # 42524
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7999
WWR#5067858 DIS
48.00 Po ATT-f
Celt' 4 8+9 0`7 73
e 437090
i
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No. 06-1774 CIVIL TERM
PATRICIA SMITH
Defendant(s)
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.
Sworn to and subscribed
before me this ij[_._
day of D e be
N ARY P B C
By:
James C. Warm r dt, Esquire
PA I.D. # 425
WELTMAN, E BERG & REIS CO., L.P.A.
1400 Koppe B Iding
436 Sevent A nue
Pittsburgh, 15219
(412) 434- 99
WWR 95067858
COMMONWEALTH OP?ENNSYLVANIA
Notarial sew
Wendy L.. Gaut. Notary Public inty
city ofCom h' AteghOM Co
15, 10'1
Asw Fjcpires July 201
ania Associatlon of ?intar ?3°
Member. PennsyN