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HomeMy WebLinkAbout06-5191 ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: C:>(. - Srql Q'lu~L'-r~ VS. COMPLAINT IN CIVIL ACTION JEFFREY D KAUFFMAN Defendant 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 05371604 C A Pit WLG \ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No JEFFREY D KAUFFMAN Defendant COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 . COMPLAINT 1. plaintiff, is a corporation with offices at 6500 NEW ALBANY ROAD NEW ALBANY , OH 43054 . 2. Defendant is adult individual(s) residing at the address listed below: JEFFREY D KAUFFMAN 329 W PENN ST CARLISLE, PA 17013 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011002060501491 . 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 August 22, 2006 , in the amount of $11330.77 . 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 $1500.00 ,I 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, JEFFREY D KAUFFMAN ,INDIVIDUALLY, in the amount of $11330.77 with interest at the legal rate of 6.000% per annum from date of judgment plus attorneys' fees of $1500.00 , and costs. James, armbrodt,42524 WELT~ WEINBERG & REIS CO., L.P.A. 436 Sev nth Avenue, Suite 2718 Pitisbu gh, PA 15219 (412) 34-7955 FAX: 4 2-338-7130 05371 04 C A Pit WLG This law firm is a debt collector a~te our client and any information obtaf d to collect this debt for be used for that purpose. payment due date July 21, 2006 $1 r"""') :'j li , ;: '":' ',I /. '..:J~ .' Please make check payable to Discover Platinum Card. Minimum payment due includes a past due amount of $2,596.00. 22 SOSN6AOl 0005294 JEFFREY KAUFFMAN 329 W PENN S1. CARLISLE PA 17013-2249 Schedule payments in advance up to your due datel To find out about our flexible and convenient online payment features, visit Discovercard.com/payments Acttress, e-mail or telephOl18 change? Print change;n space above, or go to Discovercard.com. Print your ft.-maJl address to receive important Account information and special offers. PO BOX 15251 11I",11",..1,1..1,1,11..1 WILMINGTON DE 19886-5251 1,,,111.1.,1,,1,1,,1.,11,,,1,1,,,1,1,1,1,,,,11,1,1,,,,111.1,,1 000006011002060501491113307700000001133077 . -------...-------.--------....... Discover Platinum Card Account Summary Closing Date: June 22, 2006 page 1 of 1 $11,330.77 0.00 + 0.00 + 0.00 + 0.00 + 0.00 = $11,330.n account number payment due date minimum payment due credit limit . credit available cash credit limit , cash credit available previous balance payments and credits purchases cash advances balance transfers FINANCE CHARGES new balance 6011 0020 6050 1491 July 21, 2006 $11,330.77 $9,800.00 $0.00 $0.00 $0.00 EXHIBIT .'A " Cashback Bonus. Opening Cashback Bonus Balance New Cashback Bonus Earned Cashback Bonus Balance Avellable to Redeem $ + 0.00 0.00 0.00 0.00 $ $ Cashback Bonus8 Anniversary Date: May 22 Transactions : CongratulaUons to the 20()6 NaUonaJ Discover(R) Card Tribute Award(R) Scholarship winners: Jacqueline Bavier, Stephen Carlsen, Winter Downing, Tyler Fortney, Bethany Lyon. Monika Mackow, Desiree Nelsen, Seth Robinson. WiHlam Stone, and Tess Stoops. Each won $27,500 for post high-school education or training. Visit Discovercard.com/tribute : Discovercard.com provides you with the easiest online seff-service options that put you in control of your account. .Make a paymenUoday-Of -SCtlecIuJaone.in advance.. -Sign.up for Umely-8-ma# <eminde,. Jo.IlQ/p ,"ou a""'d fees. ~y account management is just a click away! Register or log in to Discovercard.comlregister Nominal ANNUAL Transaction Average Daily ANNUAL Periodic Fee Daily Periodic PERCENTAGE PERCENTAGE FINANCE RNANCE Balances Rates RATES RATES CHARGES CHARGES current biHlng period: 3 t days Purchases $0 0.07668% 27.99% V 27.99% $0 none Cash AdvarlC8S $0 0.07668% 27.99% V 27.99% $0 $0 previous bitting period: 22 days . Purchases $0 0.07600% 27.74% V 27.74% $0 none The rates thal8QfJ/v to your Account are either fixed (F) or they may vary (V) as noled above. VERIFICATION The undersigned does hereby verify subject to the penalties of 1 g P A.C.S. ~4904 relating to Accounts Manaeer (Title) Robert Adkins . (Name) of Discover Financial Services. LLC., plaintiff herein, that (Company) unsworn falsifications to authorities, that he is he 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. ~~~~ ( ignature) ;.... WWR # 5371604 JEFFREY D KAUFFMAN 6011002060501491 l ~ .(,Q., 8 ;d (n ~ ~ """ 0 0 "'" G = " "" :1 lf1 .:, (/) ~ C~"l fn~ - ~ --0 -oh' ~ tI1 I -,)9 ..0 0' C?\C) \~ ,., ~ F .41 ~ -0 (-)C:"') ~ Zr-n c , '2- C," J~: li""- E :? ~ tfl ::!. - c:> f --- eo IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 06-5191 -CIVIL-TERM VS. PRAECIPE FOR DEF AUL T JUDGMENT JEFFREY D KAUFFMAN Defendant 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, P A 15219 (412) 434-7955 WWR#05371604 Judgment Amount $ 12830.77 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. .. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 06-5191-ClVIL-TERM JEFFREY D KAUFFMAN Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, JEFFREY D KAUFFMAN above named, in the default of an Answer, in the amount of $12830.77 computed as follows: Amount claimed in Complaint $11330.77 Interest from date of judgment at the legal interest rate of 6% per annum Attorney's fees $1500.00 $12830,77 TOTAL I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with P A R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By: WILLIA T. MO CZA PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A, 2718 Koppers Bldg. 436 Seventh A venue Pittsburgh, P A 15219 (412) 434-7955 WWR#05371604 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 329 W PENN ST CARLISLE,PA 17013 .. IN THE COURT OF COMMON PLEAS BEAVER COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff Case # O&-5J 9/- C II/It, - TelZ/rJ JEFFREY D KAUFFMAN Defendant(s) IMPORTANT NOTICE TO: JEFFREY D KAUFFMAN 329 W PENN ST CARLISLE,PA 17013 Date of Notice: WWR#: 05371604 lollI/OW 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 of Beaver 788 Turnpike Street Beaver, PA 1.5 (724) 728-4888 County BY: JAMES W PA 1. D WELT 2718 0 PITT B GH, PA (412) 434-7955 ?i ESQUIRE IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Case no: 06-5191-CIVIL- TERM Plaintiff NON-MILITARY AFFIDAVIT vs. JEFFREY D KAUFFMAN Defendant The undersigned, who first being duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter, Affiant further states that the within Affidavit is made pursuant to and m accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App, S 521. Affiant further statl~s that based upon investigation it is the affiant's belief that the Defendant, JEFFREY D KAUFFMAN 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, JEFFREY D KAUFFMAN is not in the military service. Further Affiant sayeth naught. iJL"flt{:r , AFFIANT I I SWORN TO AND SUBSCRIBED in my presence this~fJit. of b-eY .aooCo COMMONWEAI.TI-I OF PENNSYLVANIA Notarial Seal Wayne A. Jones, Notary Public City Of Pittsburgh, Allegheny County My Commission Expires June 29, 2010 Member, Pennsylvania Association of Notaries ~ This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. Request for Military Status Page 1 of2 Department of Defense Manpower Data Center . Military Status Report Pursuant to the Servicemembers Civil Relief Act OCT-23-200608:23:22 < Last Name FirstlMiddle Begin Date I Active Duty Status I Service/Agency KAUFFMAN 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, ~y.\. ~-~ Mary M, Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, V A 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 fall 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:L!}vW1Y,defeJ1Selil]k.lJ1ilLfaq!pis~C09SLDR,html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https:/ /www.dmdc.osd.mil/scra/ owa/ scra, prc _Select 10/23/2006 Request for Military Status Page 2 of2 by the requester, Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:SSIBEAXPZE https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 10/23/2006 o ?~ C CO? f.?t ~~~ c"... ,.. 0 (:-) -"'\ ~1-~~ ~ ~ ~ ~ ~ 4 ~ t- OJ. --e, ~ ~ ~ -J:: f',) -.l ::~ -..... -.- (.'1 en .. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY , PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 06-5191-CIVIL-TERM JEFFREY D KAUFfMAN 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 c)~-I ~?C ~b (xx) Assumpsit Judgment in the amount of$12830.77 plus costs. () Trespass Judgment in the amount of $_ plus costs. () Ifnot 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 A ward Prothonotary ) JEFFREY D KAUFFMAN 329 W PENN ST CARLISLE,PA 17013 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: 2006-05191 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS KAUFFMAN JEFFREY D MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within NOTICE was served upon KAUFFMAN JEFFREY D the DEFENDANT , at 0020:42 HOURS, on the 14th day of September, 2006 at 329 W PENN STREET CARLISLE, PA 17013 by handing to JEFFREY KAUFFMAN a true and attested copy of NOTICE together with COMPLAINT and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: Sworn and 18.00 4.40 .00 10.00 .00 32.40./ /0/01.//6(, ~ Subscibed to ?"'~~~ R. Thomas Kline day 09/15/2006 WELTMAN, WEINBERG & REIS By, ---:7///7~/~ -:Y~rl1f before me this of A.D. ? y i11 Li l l ar RED OCT 2 7 2011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff I S. JEFFRLY D KAUFFMAT Dcfe:.dant(s i l4IEMP?%RS iST FC;U Garnishee(i) Civil Action No. 06-5191-CIVIL-TERM ANs cA3e 4 INTERROGATORIES IN ATTACHMENT F1 i,ED ON BEHALF OF: Plaintiff C(J:?NSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WE NBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 5371604 11`i THF- COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 06-5191-CIVIL-TERM JEFFREY D'41-Al IN MAN Dei'c lidant(s) MEMBERS 1 ST FC.'.U Garnishee(s) TO: MEMBERS ; ST ICU, 1711 SPRING RD, CARLISLE, PA 17013 RE: JEFFREY 17 CAUFFMAN , 329 W PENN ST, CARLISLE, PA 17013 Suggested Ref:renc,, No.: XXX-XX-7935 XXX-XX- IMPORTANT NOTICES TO GARNISHEE! A. 'y'ou.-re required to file answers to the following interrogatories within twenty (20) days after service upon you. Fai!ure to do so may result in Judgment against you. B. I lerein, the word "defendant" means any one or more of the defendants against whom the writ of Execution is i ;sued. C. While service of Writ upon the Gar.:isjkcP attaches all property of the Defendant subject to attachment which L, 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. W WR No. 5371604 INTERROGATORIES IN ATTACHMENT !. At ?;.e time you were served or at any subsequent time did you owe the defendant any money or were you liabie to hini on any negotiable or other written instrument, or did he claim that you owed him any money or were flable to him for tiny reason (including funds on deposit for checking or savings accounts and certificates of deposit)? TA-1 ]a. ? f tl.,? answer to Interrogatory 1 is it the affirmative, state the following: the amount of money you o«e ,):- owed to defendant, and, i1-such mmiey 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 t,nd the prescat location of each of such inst1-ume11U'-L the am=ount or amounts that defendant claims or claimed that you owe or roved to him; and the nature an:! ai0ount of each of such liabilities. ???4jq-OCW447U KKX479(vM 2. At the time you were served or at any subsequent time was there in your possession, custody or control of yourself t nd one or more other persons any property of an;. nature owned solely or in part by the defendant. no 3. At ?.?le time you were served or at any subsequent time did you hold legal title to any property of any nature owned sol.ay or part by the defendant or in which defendant held or claimed any interest? 60 41. At th,: tim; you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? no At any t- me before or after you wer serve,:, did the defendant transfer or deliver any property to you or tc any person or place pursuant to your directions or consent and if so what was the consideration thereof? n b 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? nb If you are a bank or other financial institution, at the time you were served or at any subsequent time die:: ;e defendant ha%,e funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, Identify each account and state the reason for the exemption, the amount being withheld under each exemption and the amount of funds in each account, and the entity electronically depositing those funds on a recurring basis. 1n? WWR No. 5371604 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 f. nds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each ac(.ount. n? 9. If the answer to Interrogatory I is in the affirmative, state the date the sheriff served these interrogatories on this institution. 1`01211 ? 10. If the answer to Interrogatory 1 is in the aft irmative, state the date the written instrument, checking or savings acr;ount, cei-tificate of deposit, or other funds were frozen, restricted, or otherwise put on hold by this institution. I411 i I H. If the response to Interrogatory 7 is in the affirmative, are other funds comingled in the account which are not depos ted eicetronically on a recurring basis and which are identified as being funds that upon deposit are exempt from executicn, levy or attachment under Pennsylvania or federal law? no 12. If the response to Interrogatory 11 is in the affinnative, state the amount of non-exempt funds on deposit n the .3ccow;t. f) O WELTMAN, WEINBERG & REIS CO., L.P.A. By _.r Matthew. D. Urban, Esquire PA! D. 490963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Kopper.; Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR No. 5371604 A MEMBERS 1St FEDERAL CREDIT UNION October 26, 2011 Jeffrey D. Kauffman 329 West Penn Street Carlisle, PA 17013 Review Dates (60 Days): August 28, 2011 - October 26, 2011 Total Writ of Execution: $16,736.81 Cumberland County Docket Number: 06-5191 File # WWR 5371604 Account Number: XXX479-0000 Name on Account: Savings: Jeffrey D Kauffman Charise M Kauffman (Joint) $52.68 -5.00 (Membership Fee) $47.68 Payroll: Mechanicsburg Le - Charise Kauffman Mechanicsburg Le - Jeffrey Kauffman Account Number: XXX479-0011 Name on Account: Jeffrey D Kauffman Charise Kauffman (Joint) Checking: $2,210.96 -50.00 (Processing Fee) $2,160.96 $300.00 Statutory Exemption was not taken out. ?p tt? ?00/- Tania S. Yourik Deposit Operations Anal st Rev: 06/11 5000 Louise Drive - P.O. Box 40 - Mechanicsburg, Pennsylvania 17055 - (800) 283-2328 - www.memberslst.org 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 Tania S. Young (Name) Deposit Operations Analyst of Members 1st Federal Credit Union (Title) (Company) garnishee herein, that he/she is duly authorized to make this verification, and the facts set forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her knowledge, information and belief. (SIGNAT )