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HomeMy WebLinkAbout06-38181 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. DANIELLE LINE Defendant No: C>(. - '?p 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 05236992 C A Pit KMJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. DANIELLE LINE Defendant Civil Action No 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 nEbPORD STREET CARLISLE, PA 17013 (717) 249-3166 J 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: DANIELLE LINE 2305 RITNER HWY CARLISLE, PA 17013 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number'6bllo02080291263 . 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 June 22, 2006 , in the amount of $6852.50 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 $1000.00 0 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 , DANIELLE LINE individually , in the amount of $6852.50 with interest at the legal rate of 6.000% per annum from date of judgment plus attorneys, fees of $1000.00 , and costs. v - Jame C. Warmbro 42524 WEL , WEINBERG & REIS CO., L.P.A. VZ S enth Aven ue, Suite 2718 s urgh, PA 15219 434-7955 412-338-7130 6992 C A Pit KMJ 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 $ I I May 29, 2006 30 SDSN6A01 0005643 DANIELLE LINE Consolidate bills quickly and securely with a Balance Transfer to your Discover 2305 RITNER HWY Card - Call 1.877-053-0989 or visit CARLISLE PA 17013-9398 Discovercard.coMbalancetransferTODAYI PO BOX 15251 111"r11"rrr11'11r'r1"'11 WILMINGTON DE 19886-5251 Address, a-mad or telephone change? Print charge in space above, or I I I' I I ' ! ' I I I I I ?' ??? go to Discovercad.com. Print your e-mail address to receive important m r u u r u u m r w r r i u u r i u n r u Amount mlormatlon and special offers. 000006011002080291263000000000000000111{{221200 - --------------------- --- - ------------------- - - - - - - - - - - - Discover Platinum Card Account Summary Closing Date: April 30, 2006 page 1 of t account number payment due date minimum payment due credit limit credit available cash credit limit cash credit available 6011 0020 8029 1263 May 29, 2006 $1,212.00 $5,000.00 $0.00 $2,500.00 $0.00 previous balance $6,852.50 payments and credits - 6,852.50 purchases + 0.00 cash advances + 0.00 balance transfers + 0.00 FINANCE CHARGES + 0.00 new balance = $0.00 EXHIBIT x Au Cashback Bonus® Opening Cashback Bonus Balance $ 00.00 .00 New Cashback Bonus Earned Cashback Bonus Balance $ 0.00 Available to Redeem $ 0.00 Cashback Bonus® Anniversary Date: June 18 Transactions trans. post date date Payments and Credits Apr 30 Apr 30 INTERNAL CHARGE-OFF $ -6,852.50 -------------- - -------- ------- Nominal ANNUAL ---- ----------- Transaction Average Daily Daily Penodic ANNUAL PERCENTAGE PERCENTAGE Periodic Fee. FINANCE FINANCE Selances Rates RATES RATES CHARGES CHARGES current billing period: 12 days 'Purchases $0 0.06847% 24.99% F 24.99% $0 none Cash Advances $0 0.06847% 24.99% F 24.99% $0 $0 The rates that aooly to your Amami are ximar fixed IR or thev may varV M as noted above. I'LL n JUN 1 3 2006 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unswom falsifications to authorities, that he/she isit?C? ?S /? (Name) f-YCEI?i??-of Discover Financial Services LLC., plaintiff herein, that { (Title) (Company) he/she is duly 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# 5236992 DANIELLE LINE 6011002080291263 V d F ?? Yl T_ -n V `I CIZ ? f-`. rO l ro ai 4,1 I, loll IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION No. 06-3818 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOLCZAN, ESQUIRE PA I.D.447437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWRN05236992 Judgment Amount S 7,852.50 DISCOVER BANK Plaintiff vs. DANIELLE LINE Defendant THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. it I-,I of, ,' ii11 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 06-3818 CIVIL TERM DANIELLE LINE Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, DANIELLE LINE above named, in the default of an Answer, in the amount of $7,852.50 computed as follows: Amount claimed in Complaint $6,852.50 Interest from date of judgment at the legal interest rate of 6% per annum Attorney's fees $1,000.00 TOTAL $7,852.50 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By: °v ' - I' WILLIAM T. MOLCZAN, SQUIRE PA 1.D.#47437 Welnuan, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05236992 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 70'Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 2305 RITNER HWY., CARLISLE,PA 17013 . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA t' CIVIL DIVISION r DISCOVER BANK Plaintiff DANIELLE LINE Defendant(s) IMPORTANT NOTICE TO: DANIELLE LINE 2305 RITNER HWY CARLISLE,PA 17013 Date of Notice: 0g- d7O WWR#: 05236992 Case # 0b - 3klg Cs? L rego, YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 G BY: Qr- ?/ JAM$ WARMBRODT, ESQUIRE PA 1-1. #42524 WEST API, WEINBERG & REIS CO., L.P.A. 2 KOPPERS BLDG, 436 7TH AVE. TSBURGH, PA 15219 IN THE COTZMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL. DIVISION DISCOVER BANK Case no: 06-3818 CIVIL TERM Plaintiff NON-MILITARY AFFIDAVIT VS. DANIELLE LINE 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.I 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, DANIELLE LINE is not in the military service. Affiant further Mates that this belief is supported by the attached certificate from the Defense Manpower Data 1 Center (DMDC), which states that the Defendant, DANIELLE LINE is not in the military service. Further Affiant sayeth naught. AFFIANT SWORN TO ND SUBSCRIBED in my presence this 2 1 day E, of-- - N 20C)l - COMM IALTN OR P,2N,N VANIA Notarlal8eal NO ARYPU IC CkyOfPMWuryh,A ,y County My 0mvnbdon B0m J"28, 21110 Mamba, Penna*wla Aswdatlon of NOW" 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. I,.,4$1 Request for Military Status Department of Defense Manpower Data Center ta. Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 AUG-21-2006 05:51:18 L Last Name First/Middle Begin Date Active Duty Status Service/Agency LINE 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. Mary M. Snavely-Dixon, 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 Servicemembers Civil Relief Act [50 USCS Appx. # 167;# 167; 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:'/41RNv.delen,selink mi]/faq/t)isiPC09SL I)_R.htm:.1 WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmde.osd.mil/sera/owa/scra.prc_Select 8/21/2006 A Request for Military Status by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Page 2 of 2 Report ID:BFIXYPAAQSL https://www.dmdc.osd.mil/scra/owa/scra.prc-Select 8/21/2006 II r , . IN THE COURT OP COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL. DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 06-3818 CIVIL TERM DANIELLE LINE Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order r Judgment was entered against you on (xx) Assumpsit Judgment in the amount of $7,852.50 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: PRO ONOTA DANIELLE LINE 2305 RITNER HWY CARLISLE,PA 17013 Plaintiffs address is: c/o Wellman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7" Avenue, Pittsburgh, PA 15219 1-888-434-0085 -14 P, 4I n i k SHERIFF'S RETURN - REGULAR CASE NO: 2006-03818 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS LINE DANIELLE SHANNON SHERTZER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LINE DANIELLE the DEFENDANT , at 1900:00 HOURS, on the 10th day of July 2006 at 2305 RITNER HIGHWAY CARLISLE, PA 17013 by handing to CLARENCE LINE, FATHER 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 Service Affidavit Surcharge 4- Sworn and Subscibed to before me this of So Answers: 18.00 4.40 .00 10.00 R. Thomas Kline .00 32.40/ 07/11/2006 ryl,Io? WELTMAN WEINBERG REIS By. w day Deputy S eriff A. D. IL ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. DANIELLE LINE Defendant MEMBERS I ST FCU, Garnishee, No. 06-3818 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 WR#05236992 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 06-3818 CIVIL TERM DANIELLE LINE Defen&nt MEMBERS 1 ST ECU, 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: 2. against DANIELLE LINE, Defendant ,13 05 Rkner +1" , Ca.rtt3fe , PA llom 3. against MEMBERS Is' ICU, Garnishee 5 opo Louise Dr, Meth , PA 11055- 00410 4. Judgment Amount $ 7852.50 Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): $ 413.08 $ 8265.58 WELTMAN, W IINNBERG & REIS CO., L.P.A. By: William T. Molczdn, uire 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#05236992 1 ? .o 0 N a V ?4-- 0 ,64 Oa Q F a r n ID: 4, r C> LA :.o 00 0 O > c o w cz 0 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 06-3818 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s) From DANIELLE LINE, 2305 RITNER HIGHWAY, CARLISLE, PA 17013 (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: MEMBERS 1sT FCU, 5000 LOUISE DRIVE, MECHANICSBURG, PA 17055-0040 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 $7,852.50 L.L. $.50 Interest $413.08 Atty's Comm % Due Prothy $2.00 Atty Paid $123.90 Other Costs Plaintiff Paid Date: 8/01/07 Curtis . Long, Pro (Seal) 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: 412-494-7955 Supreme Court ID No. 47437 L, ? l WWR#05236992 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. DANIELLE LINE Defendant and MEMBERS 1 ST FCU Garnishee No. 06-3818 CIVIL TERM Aft6u?e,-6 4/ INTERROGATORIES IN ATTACHMENT MEMBERS 18T FCU 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 WWR905236992 tr IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. DANIELLE LINE Defendant and MEMBERS I ST FCU Garnishee TO: MEMBERS 1sT FCU 5000 LOUISE DRIVE MECIAMCSBURG, PA 17055-0040 Civil Action No.: 06-3818 CIVIL TERM Suggested Reference No.: XXX-XX-3401 RE: DANIELLE LINE 2305 RITNER HWY CARLISLE,PA 17013 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? L, I a. 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 teat you owe or owed to him; and the nature and amount of each of such liabilities. 2. At the time you were served or alt 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. 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? 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? P,? c-) 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? 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? r<', C) 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 bass and which are identified as being fundk that upon deposit are exempt from execution, lew 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. p?,J N e 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 exempt fields, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. WELTMAN, WEINBERG & REIS CO., L.P.A. By: e w William T. Molcza , Es ire PA I.D. 447437 WELTMAN, WEINBBR.G & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05236992 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 M 'A ?ff) W0 b M1 1 l ` (Name) of 4-Q garnishee herein, (Title) (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. SIG URE n X7 _t3 f!7 -t SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-03818 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND DISCOVER BANK VS LINE DANIELLE And now MICHAEL BARRICK ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0016:30 Hours, on the 7th day of August , 2007, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT LINE DANIELLE hands, possession, or control of the within named Garnishee MEMBERS FIRST FCU 5000 LOUISE LANE MECHANICSBURG, PA 17055 Cumberland County, Pennsylvania, by handing to DAWN SULLIVAN (SUPPORT SPECIALIST) personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to Her . in the true and made Sheriff's Costs: So answers: Docketing .00 'Ooze f - Service .00 Affidavit .00 R. Thomas Kline Surcharge .00 Sheriff of Cumberland County .00 . 00 08/10/2007 Sworn and Subscribed to before me this day of By Deputy Sheriff A.D IN THE C? URT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. DANIELLE LINE Defendant MEMBERS 1 IT FCU Garnishee No. 06-3818 PRAECIPE TO SETTLE, DISCONTINUE & END AS TO THE GARNISHEE MEMBERS 1 ST FCU ONLY FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05236992 r` IN THE DISCOVER BANK Plaintiff VS. DANIELLE LINE Defendant MEMBERS 1 ST FC Garnishee TO THE Please kindly FCU, only, upon the T OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Civil Action No. 06-3818 _MMCIPE TO SETTLE DISCONTINUE AND END AS TO THE GARNISHEE, MBERS 1 FCU, ONLY A,RY OF COUNTY: Discontinue and End the above captioned matter as to Garnishee, MEMBERS 1sT s of the Court and mark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By. LeMl "- • I - William . Moldan, 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#05236992 Sworn to and s Before me the Day of AUG/fU/ fsls.c U' i Y T, 00 g OVA v A,JWC,N0WyPl?bdc L ? 00 A- t=o. R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff's Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pone Sale Certified Mail Postage Garnishee TOTAL Advance Costs: 150.00 Sheriff's Costs 92.94 18.00 55.20 1.86 .50 2.00 Refunded to Atty on 04/02/08 13.44 30.00 20.00 9.00 92.9 '--1/2 310 d' So Ansi`? R. Thomas Kline, Sheriff ? By. C?? 63SGi Nr'RI I' OF EXL( I I'10N :?uti,oa ( I I (('ti,?iv\ ('OMMONWF:ALTII OF PENNSYI VANLy1 ('01 NTY OF Ct;MBFRI_AND) \()00-38)h ('ivil I I I 3C 1[+) N? ? ??+ TO THE SHERIFF OF CUMBERLAND COL`N'l Y: To satisfy the debt. interest and costs due DISCOVER BANK Plaintiff (s) From DANIELLE LINE, 2305 RITNER HIGHWAY, CARLISLE, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sel l (2) You are also directed to attach the property ofthe defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: MEMBERS 1sT FCtl, 5000 LOUISE DRIVE, MECHANICSBURG, PA 17055-0040 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 $7,852.50 1,. L. $.50 Interest $413.08 Atty's Comm `%b Due Prothy $2.00 Atty Paid $123.90 Other Costs Plaintiff Paid Date: 8/01/07 *k /y Curtis R. Long, Prothoo `otary (Seal) 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: 412-494-7955 Supreme Court ID No. 47437