HomeMy WebLinkAbout06-2821IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
VS.
CHRISTOPH J HALL
Defendant
No : (No - ;Z pa I
(2,v; t?
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
05076544 C A Pit KEB
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
VS. Civil Action No
CHRISTOPH J HALL
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, CAPITAL ONE BANK is a corporation with offices at 6851
JERICHO TURNPIKE #190 SYOSSET , NY 11791 .
2. Defendant is adult individual(s) residing at the address listed
below:
CHRISTOPH J HALL
99 MOUNTAIN LN
NEWBURG, PA 17240
3. Defendant applied for and received a credit card bearing the
account number 5291491592417610 .
,t,card and has a current balance
4. Defendant made use of said credi
due of $8836.25 , as of May 08, 2006 .
5. Defendant is in default by failing to make monthly payments when
due. As such, the entire balance is immediately due and payable to
Plaintiff.
6. Plaintiff is entitled to the addition of interest at the rate of
19.8005 per annum on the unpaid balance from May 08, 2006 . A copy of
Plaintiff's APPLICATION is attached hereto, marked as Exhibit I'll, and
made a part hereof.
y
7. 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 , CHRISTOPH J HALL , INDIVIDUALLY , in the amount of
$8836.25 with continuing interest thereon at the rate of 19.800% per
annum from May 08, 2006 plus costs.
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James armbrodt,42' 4
WELT WEINBERG & REIS CO., L.P.A.
436 v nth Avenue, Suite 2718
Pit b rgh, PA 15219
(41 j 34-7955
F 12-338-7130
0 7 544 C A Pit KEB
This law firm is a debt collector attAX*ting to collect this debt for
our client and any information obtained will be used for that purpose.
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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 :SP' m e I
(NAME)
of r " ?vLG_.. plaintiff herein, that
(TITLE) - (COMPANY)
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.
(SIG ATURE)
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK,
Plaintiff
vs.
CHRISTOPH J HALL
Defendant
No. 06-2821 CIVIL TERM
PRAECIPE FOR DEFAULT JUDGMENT
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#05076544
Judgment Amount $ 9114.27
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
CAPITAL ONE BANK,
Plaintiff
vs. Civil Action No. 06-2821 CIVIL TERM
CHRISTOPH J HALL
Defendant
TO THE PROTHONOTARY:
PRAECIPE FOR DEFAULT JUDGMENT
Kindly enter Judgment against the Defendant, CHRISTOPH J HALL above named, in the default of an
Answer, in the amount of $9114.27 computed as follows:
Amount claimed in Complaint
$8836.25
Interest from 05/0806
at the legal interest rate of 19.80% per annum $278.02
TOTAL $9114.27
1 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:
WILLIAM T. MOL AN, QUIRE
PA I.D.#47437
Weltman, Weinberg & Reis Co., L.P.A.
2718 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#05076544
Plaintiffs address is:
c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219
And that the last known add!iess of the Defendant is: 99 MOUNTAIN LN
NEWBURG,PA 17240
1
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
CHRISTOPH J HALL
Defendant(s)
IMPORTANT NOTICE
TO: CHRISTOPH J HALL
99 MOUNTAIN LN
NEWBURG,PA 17240 r,
Date of Notice: WWR#: 05076544
Case # 0&- o?2S21 CkVL(-,(r('7'1-
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 W BRO'DT, I ESQUIRE
PA I.D 42524
WEL WEINBERG & REIS CO., L.P.A.
2718 K PERS BLDG, 436 7TH AVE.
PIT S GH, PA 15219
IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK,
Plaintiff
VS.
CHRISTOPH J HALL
Defendant
Case no: 06-2821 CIVIL TERM
NON-MILITARY AFFIDAVIT
The undersigned, who first being duly sworn, according to law, deposes and states as follows:
That he/she is the ly authorized agent of the Plaintiff in the within matter.
Affiant further Ittes 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, CHRISTOPH J
HALL 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, CHRISTOPH J HALL is not in the military service.
Further Affiant sayeth naught. ---?/? ---.--
AFFIANT
SWORN TO A
of ?'?.`?
NOTXRY PUBLIC
my presence this !day
L. Gault, Notary Public
sburgh, Allegheny County
rV'H'Pq JUIV 151 2006
e.?YU:. nw .'r4? 14 { F R.??
This law firm is a debt collector attempting to collect this debt for our client alpd 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 Servicemembers Civil Relief Act
Page 1 of 2
JUL-05-2006 11:25:38
-16 Last Name First/Middle Begin Date Active Duty Status! Service/Agency
HALL CHRISTOPH 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, based
on the information that you provided, the above is the current status of the individual as to all branches
of the Military.
r
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 (D$ERS) 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 Servicemembers 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 strongly
encouraged to obtain further verification of the person's active duty status by contacting that person's
Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on
active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA
may be invoked against you.
If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle
name), you can submit your request again at this Web site and we will provide a new certificate for that
query.
This response reflects current active duty status only. For historical information, please contact the
Military Service SCRA points-of-contact.
See: http://www.defenseIink.mil/faq/pisfPC09SLDR.htmi
WARNING: This certificate was provided based on a name and Socials Security number (SSN) provided
https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 7/5/2006
Request for Military Status
Page 2 of 2
by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided.
Report ID:KHHIRFFDHE,
https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 7/5/2006
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IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK,
Plaintiff
vs. Civil Action No. 06-2821 CIVIL TERM
CHRISTOPH J HALL
Defendant
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the following
Order or udgment was entered against you
on I aC>6(s
(xx) Assumpsit Judgment in the amount
of $9114.27 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
(xx) Default
( ) Verdict
( ) Arbitration
Award
Prothonotary
By: P,4
P(OR-DEPttf
)
CHRISTOPH J HALL
99 MOUNTAIN LN
NEWBURG,PA 17240
Plaintiffs address is:
c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219
1-888-434-0085
SHERIFF'S RETURN - REGULAR
CASE NO: 2006-02821 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CAPITAL ONE BANK
VS
HALL CHRISTOPH J
WILLIAM CLINE
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
HALL CHRISTOPH the
DEFENDANT , at 1630:00 HOURS, on the 26th day of May , 2006
at 99 MOUNTAIN LANE
NEWBURG, PA 17240
KATY MARSHALL, ROOMMMATE
by handing to
ADULT IN CHARGE
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 18.00
Service 17.60
Affidavit .00
Surcharge 10.00
.00
45.60,/
Qrw, 7/110
Sworn and Subscibed to
before me this day
So Answers:
R. Thomas Kline
05/30/2006
WELTMAN WEINBERG REIS
By: ??. a//w
Deputy Sheriff
of A. D.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
vs.
CHRISTOPH J HALL
Defendant
MEMBERS FIRST FCU,
Garnishee,
No. 06-2821 CIVIL TERM
PRAECIPE FOR WRIT OF EXECUTION
(BANK ATTACHMENT and LEVY)
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#05076544
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
vs. Civil Action No. 06-2821 CIVIL TERM
CHRISTOPH J HALL ?cA mt?Jt'l?c?,,/1 -n% Ue('?t]` r, T NO
Defendant _
MEMBERS FIRST FCU, - ? G ?? `}'? ???? ''h?F??V z
Garnishee
TO THE PROTHONOTARY:
PRAECIPE FOR WRIT OF EXECUTION
Kindly issue a Writ of Execution in the above matter...
1. directed to the Sheriff of CUMBERLAND County:'?? ?z?? uk:?r; C(G1??S`2
L
2. against CHRIS"hOPH J HALL, Defendant c -? -
3. against MEMBERS FIRST FCU, Garnishee
4. Judgment Amount $ -444?7 799AI- 37
Less payments of $ (1119.90)
Interest $ 330.85
Costs $
SUBTOTAL: $ 8325,22
Costs (to be added by Prothonotary): $
WELTMAN, WEINBERG & REIS CO., L.P.A.
By: ? -
William T. Molczan, Esq ' e
PA I.D. 447437
WELTMAN, WEINBERG & REIS CO.. L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#05076544
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 06-2821 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION -- LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CAPITAL ONE BANK Plaintiff (s)
From CHRISTOPH J HALL, 99 MOUNTAIN LN, NEWBURG, PA 17240
(1) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON ANY/ALL
DEFENDANT'S PROPERTY.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
MEMBERS FIRST FCU, 105 W KING ST, SHIPPENSBURG, PA 17257
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 $7994.37 L. L. $.50
Interest $330.85
Atty's Comm %
Due Prothy $2.00
Atty Paid $137.10 Other Costs
Plaintiff Paid
Date: 04-18-07
Curtis F/ Long, Proth ary
(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: 412-434-7955
Supreme Court ID No. 47437
l-f
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
VS.
CHRISTOPH J HALL
Defendant
and
MEMBERS FIRST FCU
Garnishee
No. 06-2821 CIVIL TERM
1q-A5 w e.-5 IV,
INTERROGATORIES IN ATTACHMENT
MEMBERS FIRST FCU
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#05076544
4. .
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
VS.
CHRISTOPH J HALL
Defendant
and
MEMBERS FIRST FCU
Garnishee
Civil Action No.: 06-2821 CIVIL TERM
TO: MEMBERS FIRST FCU Suggested Reference No.: XXX-XX-2556
105 W KING ST
SHIPPENSBURG PA 17257
RE: CHRISTOPH J HALL
99 MOUNTAIN LN
NEWBURG,PA 17240
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.
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? , I O
2. If the answer to Interrogatory I 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.
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. N O
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.
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?
k
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.
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? ? O
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.
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.
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? A O
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.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
William T. Molczan, EAuire
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
W WR#05076544
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
vs.
CMUSTOPH J HALL
Defendant
and
MEMBERS FIRST FCU
Garnishee
No. 06-2821 CIVIL TERM
AnSwerS 4r-) C) ? 0
INTERROGATORIES IN ATTACHM IT ° -n
MEMBERS FIRST FCU' - s
171
c)
`1 C"rl
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#05076544
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IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
vs.
CHRISTOPH J HALL
Defendant
and
MEMBERS FIRST FCU
Garnishee
Civil Action No.: 06-2821 CIVIL TERM
TO: MEMBERS FIRST FCU Suggested Reference No.: XXX-XX-2556
105 W KING ST
SHIPPENSBURG PA 17257
RE: CHRISTOPH J HALL
99 MOUNTAIN LN
NEWBURG,PA 17240
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.
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?
0
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.
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. I V O
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.
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?
lob
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.
AcfA'--* 18q 2.O'&rc?ov???r
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? 00
0
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.
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.
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? 00
0
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.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By
William T. Molczan, EAuire
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#05076544
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2006-02821 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
CAPITAL ONE BANK
VS
HALL CHRISTOPH J
And now RICHARD SMITH
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0012:25 Hours, on the 27th day of April , 2007, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
HALL CHRISTOPHER
hands, possession, or control of the within named Garnishee
MEMBERS FIRST FCU 1166 WALNUT BOTTOM ROAD
, in the
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
BRIAN PETERS (MANAGER)
personally three copies of interogatories together with 3
and attested copies of the within WRIT OF EXECUTION
the contents there of known to His
Sheriff's Costs:
Docketing .00
Service .00
Affidavit .00
Surcharge .00
00
s/ai fb 9 ? .00
Sworn and Subscribed to
before me this day of
true
and made
So a
rarr`?
R. Thomas Kline
Sheriff of Cumberland County
05/18/2007 r,
By
Deputy Sheriff
A.D
R. Thomas Kline, Sheriff, who being duly sworn according to law, states
this writ is returned STAYED, DUE TO BANKRUPTCY.
Sheriff's Costs: Advance Costs: 150.00
Sheriff's Costs: 136.17
Docketing $ 18.00 163.83
Poundage 2.67
Advertising
Law Library .50
Prothonotary 2.00 Refunded to Atty on 06/13/07
Mileage 24.00
Surcharge 40.00
Levy 40.00
Post Pone Sale
Garnishee 9.00
Postage
TOTAL $
136.17
? ?1° ??7 So Ans ers•
R. Tho as Kline, Sheriff
By
1
PQ L? ` ?? U'.I is :?? ,
-55'D 5k F qj,
r
?o
1
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-2821 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CAPITAL ONE BANK Plaintiff (s)
From CHRISTOPH J HALL, 99 MOUNTAIN LN, NEWBURG, PA 17240
(1) You are directed to levy upon the property of the defendant (s)and to sell LEVY ON ANY/ALL
DEFENDANT'S PROPERTY.
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
MEMBERS FIRST FCU, 105 W KING ST, SHIPPENSBURG, PA 17257
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 $7994.37 L.L. $.50
Interest $330.85
Atty's Comm % Due Prothy $2.00
Atty Paid $137.10 Other Costs
Plaintiff Paid
Date: 04-18-07
Cit6is R. , rothonotar}/
(Seal) By: (//J
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
I
(7) r.,
`- `' C)
C3
r?
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANU
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
VS.
CHRISTOPH J HALL
Defendant
MEMBERS FIRST FCU
Garnishee
No. 06-2821 CIVIL TERM
PRAECIPE TO SETTLE, DISCONTINUE
& END AS TO THE GARNISHEE
MEMBERS FIRST FCU ONLY
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 15219
(412) 434-7955
WWR#5076544
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK
Plaintiff
vs.
CHRISTOPH J HALL
Defendant
MEMBERS FIRST FCU
Garnishee
Civil Action No. o6-2821 CIVIL TERM
PRAECIPE TO SETTLE DISCONTINUE AND END
AS TO THE GARNISHEE, MEMBERS FIRST FCU, ONLY
TO THE PROTHONOTARY OF COUNTY:
Please kindly Settle Discontinue and End the above captioned matter as to Garnishee, MEMBERS FIRST FCU,
only, upon the records of the Court and mark the cost paid.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
James
t r
odt
PA I.D
WELT EINBERG & REIS CO., L.P.A.
2718 K
/ uilding
436 Se
th enue
Pittsbu 15219
(412) 4 6544
t',r,
tarie-
Sworn to and subscribed
Before me the
Day of SEPTEMBER
nnnn
06
0 c.J
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