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
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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
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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
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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