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HomeMy WebLinkAbout06-7168i f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. DANELLE D OCONNOR Defendant No : QL~ - L lCO U (~ ~ ~~ c~ 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 05570324 C A Pit WLG .- ' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No DANELLE D OCONNOR 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: DANELLE D OCONNOR 190 ALTERS RD CARLISLE, PA 17015 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011002470328774 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 November 29, 2006 in the amount of $2045.39 5. Defendant is in default by failing to make payments when due. 6. Plaintiff avers that the Agreement between the parties provides that Defendant will pay Plaintiff's attorneys' fees. 7. Plaintiff avers that such attorneys' fees will amount to $300.00 . 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 DANELLE D OCONNOR ,INDIVIDUALLY in the amount of $2045.39 with interest at the legal rate of 6.000 per annum from date of judgment plus attorneys' fees of $300.00 and costs. Jame Warmbrodt,42524 WELT WEINBERG & REIS CO., L.P.A. 436 Se enth Avenue, Suite 2718 Pi tsb rgh, PA 15219 (4 2) 434-7955 F 412-338-7130 0 5 0324 C A Pit WLG This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. ~~~~~ ~~M ~~y S2,045.39w ~~ 20 SDSN6A01 0007340 DANELLE OCONNOR 190 ALTERS RD CARLISLE PA 17015-7737 ..................,r..,...,, ..~.. I ,......,..,., ........,... .,,......,_, ....._ .... $235.16 Enter Amount Enclosed Below Payment Due Date ~ ~ ~ `~,r`~ ~,'~y1 ~ ,~ October 19, 2006 please make check payable to Discover Card. You are overlimit. Pay the sum of the monthly minimum payment plus the overlimit amount of $545.39. ~. ~ ~ ~, Save time and a stamp this month by paying your bill online. To find out about our free and flexible online payment features, visit D iscovercard.com/payments Address, email or telephone chanse6 Print chance in space above, or go to Discovercard.com, Print your e-mail address to receive important Account information and special offers. PO BOX 15251 ~~~~r~~~rrrr~~~~~~~u~n~r~ WILMINGTON DE 19886-5251 ~u~~~~i~u~n~i~u~u~~ni~i~ni~~~i~i~un~~~~~~un~~~~~n~ D00006011002470328774020453900000000023516 ~~'~° Discover Card Account Summary : ~~~----y - Closing Date: September 20, 2006 page 1 of 2 'Account Number 601 1 0024 7032 8774 Previous Balance $1 958 86 Payment Due Data October 19, 2006 Payments And Credits , . - 0 00 Minimum Payment Due $235.16 Purchases . + 39 00 Credit Limit $1,500.00 Cash Advances . + 0 00 Credit Available $-545.00 Balance Transfers . + 0 00 Cash Credit limit $800.00 Finance Charges . + 47 53 Cash Credit Available $0.00 New Balance $2,045.39 You may be able to avoid Periodic Finance Charges, see the reverse side For details. Cashback Bonus® Opening Cashback Bonus Balance $ 0.00 New Cashback Bonus Earned + 0,00 Cashback Bonus Balance $ 0.00 Cashback Bonus® Anniversary Available to Redeem $ 0..00 Date: July 20 How Can We Help You? For Account Inquiries, writs to us at: Please have your Discover Card available. Discover Card, PO Box 30943 Solt Lake City, UT 84130 Manage your account online at Discovercard.com TDD (Telecommunications Device for the Deaf): ~Customsr Service: 1-800-DISCOVER (1-800-347-2683) For assistance, see reverse side. 'Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence. Trans. Post Dale Date CNher/Miscellaneous Sep 20 Sep 20 LATE FEE $ 39.00 ;Information For You The address provided in your Cardmember Agreement to request a beneficiary designation Form for your Scheduled Air Travel Accident Insurance has changed. The new address is AIG Accident & Health Division, 300 South Riverside Plaza, .Suite 2100, Chicago, Illinois 60606-6613, ',Your Account is overlimit. While we are permitted under the Cardmember Agreement to charge you an Overlimit Fee, we ;have chosen not to do so at this time. We reserve the right to do so if, as of the close of a billing period, your outstanding 'Account balance exceeds your Account credit limit. Sae the Overlimit Fee section of the Cardmember Agreement For details. ******* ATTENTION ******* ATTENTION ******* ATTENTION ******* ATTENTION ******* ATTENTION * * * * * * * Your account is seriously past due. Payment of the amount due and arrangements for future payments should be made immediately. ,- - • ~,. VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsifications to authorities, that he is Robert Adkins (Name) Accounts Manager of Discover Financial Services LLC., plaintiff herein, that (Title) (Company) 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. r . -- (Signature) WWR # 5570324 DANELLE D OCONNOR 6011002470328774 ~ r r^^ v( ~ ~ v ` ~ ~' n ~ ~ a t.Y'~ ,~ f~T't t- ~ i f~ r, ~ :a _ ~ ~ ~ ) )CY r O _ '~z . 3 ~:: a ` _ _ C.,,J .. ? 1..~'i =.~ ~:~ ,~-" _e ,~- -t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL DIVISION DISCOVER BANK Plaintiff vs. DANELLE D OCONNOR Defendant No. 06-7168 CIVIL PRAECIPE FOR DEFAULT NDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Patrick Thomas Woodman,Esquire PA LD. # 34507 Weltman,Weinberg &Reis,Co. 2718 Koppers Building 436 Seventh Avenue Pittsburgh,Pa 15219 Judgment Amount $ 2,345.39 W WR No. W WR# 05570324 [N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA C[V[L DIVISION DISCOVER BANK Plaintiff vs. DANELLE D OCONNOR Defendant TO THE PROTHONOTARY: Civil Action No. 06-7168 CIVIL PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, Danelle D Oconnor ,above named, in the default of an Answer, in the amount of $2,345.39 computed. as follows: Amount claimed in Complaint $ 2,045.39 Interest at the rate of 6% from date of judgment plus costs $ Attorney Fees TOTAL $ 300.00 $ 2,345.39 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: ~a~,t.. _ ~l~e~-- Patrick Thomas Woodman,Esquire PA I.D. # 34507 Weltman,Weinberg &Reis,Co. 2718 Koppers Building 436 Seventh Avenue Pittsburgh,Pa 15219 WWR#WWR# Plaintiff s address is: c/o Weltman, Weinberg & Reis, 2708 Koppers Bldg., 436 7~` Ave., Pittsburgh, PA 15219 WWR No. WWR#05570324 And that the last known address of the Defendant: Danelle D Oconnor , 190 Alters Rd Carlisle,Pa 17015 WWRNo. WWR# 05570324 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOV ER BANK Plaintiff vs. Civil Action. No. 06-7168 CIVIL DANELLE D OCONNOR 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 ~ '.ZQip7 t (xx) Assumpsit Judgment in the amount of $2,345.39 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 Danelle D Oconnor 190 Alters Rd Carlisle,Pa 17015 _ By: PR HO A Y ) WWR No. WWR# 05570324 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, that the parties against whom Judgment is to be entered according to the Praecipe attached are not members of the Armed Forces of the United States or any other military or non-military service covered by the Soldiers and Sailors Civil Relief Act of 1940. The undersigned further states that the information is true and correct to the best of the undersigned's knowledge and belief and upon information received from others. WELTMAN, WEINBERG & REIS CO., L.P.A. gy: ~rz- /~o~w G~,b~2~~-- Patrick Thomas Woodman,Esquire PA I.D. # 34507 Weltman,Weinberg &Reis,Co. 2718 Koppers Building 436 Seventh Avenue Pittsburgh,Pa 15219 WWRNo. WWR#05570324 Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 APR-09-2007 05:49:30 ~ Last Name First/Middle Begin Date Active Duty Status Service/Agency OCONNOR DANELLE 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//www.defenselink.mil/faq/pis/PC09SLDR.htm1 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 4/9/2007 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: CGEIFYEMEVZ https://www.dmdc.osd.miUscra/owa/scra.prc_Select 4/9/2007 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff DANELLE D OCONNOR Defendant 06-7168 CIVIL TERM IMPORTANT NOTICE TO: Danelle D Oconnor 1.90 Alters Rd Carlisle,Pa 17015 ; _ Date of Notice: 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 TH1:S 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFEKRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A. By:~i ~.~- t 1no+nr~oa Apo Patrick Thomas Woodman,Esquire PA I.D. # 34507 Weltman,Weinberg &Reis,Co. 2718 Koppers Building 436 Seventh Avenue Pittsburgh,Pa 15219 W WR #05570324 F -~.. cam. '~.. ( _ .-,... ~^ ~4 ~C d '~ -~---, `, r. n c' ;''`~~: ~' ,.:_ -F-`s `. <:~ ,.~ c~ v ~3 ~~ ~;a ~ a -r, ~~{ ,`°~ {n ~cy :~ SHERIFF'S RETURN - REGULAR CASE NO: 2006-07168 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS OCONNOR DANELLE D JASON VIORAL Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon nrnrTrTno r~rnT~r.r.~ n the DEFENDANT at 1503:00 HOURS, on the 27th day of December 2006 at 190 ALTERS ROAD CARLISLE, PA 17015 by handing to DANELLE OCONNOR a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof Sheriff's Costs: Docketing Service Affidavit Surcharge ~l~yJ61 So Answers: 18.00 4 . 4 0 ' i'~'''~ .00 10.00 R. Thomas Kline .00 32.40 12/28/2006 WELTMAN WEINBERG REIS Sworn and Subscibed to before me this of day BY : ~ ~ .,~. -.. Dep Sheriff A.D. ~. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-7168 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s) From DANIELLE D. OCONNOR AT 162 LINCOLN STREET 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 MEMBERS 1sT FEDERAL CREDIT UNION AT 1,711 SPRING ROAD CARLISLE, PA 17013 GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $2,345.39 L.L. $.50 Interest $444.17 Arty's Comm % Due Prothy $2.00 Atty Paid $129.90 Other Costs TO BE ADDED Plaintiff Paid Date: 12/15/10 kai U _ David D. Buell, Pro / (Seal) By: AMUM Deputy REQUESTING PARTY: Name MATTHEW D. URBAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., L.P.A 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLANTIFF Telephone: 412-434-7955 Supreme Court ID No. 90963 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. DANELLE D OCONNOR Defendant MEMBERS I ST FEDERAL CREDIT UNION, Garnishee, ?1 SG Aj? u vbl i L/O e&7 1$ I y. 0 v ?aSG pa A4JJ U ? w O 6; No. 06-7168-CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#5570324 n c , o o -n - -gy ?? m -?> o0 ?d ? -n N ru n co IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. DANELLE D OCONNOR Defendant MEMBERS 1 ST FEDERAL CREDIT UNION, Garnishee TO THE PROTHONOTARY: Civil Action No. 06-7168-CIVIL TERM 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 Danelle D. OConnor, 162 Lincoln St, Carlise, PA 17013, Defendant 3. against Members 15t Federal Credit Union, 1711 Spring Road, Carlisle, PA 17013, Garnishee 4. Judgment Amount $ 2,345.39 Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): $ 444.17 $ 2,789.56 ;WELTMAN, ERG & REIS CO., L.P.A. Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ?tt??ip of ?t??f f3r 1?f ('e? Jody S Smith ri5E Chief Deputy ?81 if f0 "4 Richard W Stewart Solicitor Discover Bank vs. Danelle Dawn OConnor Case Number 2006-7168 SHERIFF'S RETURN OF SERVICE 01/03/2011 02:50 PM - Tim R. Black, Deputy Sheriff, who being duly sworn according to law, states that on January 3, 2011 at 1450 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Danelle Dawn OConnor, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1166 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Marisol Barber, Branch Manager, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on January 4, 2011 to Danelle D. OConnor, 162 Lincoln Street, Carlisle, PA 17013. SO ANSWERS, i January 04, 2011 RON R ANDERSON, SHERIFF Ti R, Black, Deputy COi a 6. tc he-:V c rc , t RECEIVED JAN 0 3 2011 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. DANELLE D OCONNOR Defendant and MEMBERS 1 ST FEDERAL CREDIT UNION Garnishee No. 06-7168-CIVIL TERM INTERROGATORIES IN ATTACHMENT MEMBERS 1sT FEDERAL CREDIT UNION FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: ? N Matthew D. Urban, Esquire: PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#5570324 0 rn ? c? A IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. DANELLE D OCONNOR Defendant and MEMBERS I ST FEDERAL CREDIT UNION Garnishee Civil Action No.: 06-7168-CIVIL TERM TO: Members I" Federal Credit Union Suggested Reference No.: XXX-XX-6900 1711 Spring Road Carlisle, PA 17013 RE: DANELLE D OCONNOR 162 LINCOLN STREET 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 (including funds on deposit for checking or savings accounts and certificates of deposit)? No I a. 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. 1v \ 2. 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. Nb 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? 00 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? 00 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? 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 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. 1 1? 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 funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If so, identify each account. 9. If the answer to Interrogatory I is in the affirmative, state the date the sheriff served these interrogatories on this institution. 10. If the answer to Interrogatory 1 is in the affirmative, state the date the written instrument, checking or savings account, certificate of deposit, or other funds were frozen, restricted, or otherwise put on hold by this institution. 11. If the response to Interrogatory 7 is in the affirmative, are other funds comingled in the account which are not 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? 0, ? 12 deposit in the account. 0' WELTMAN, WEINBERG & REIS CO., L.P.A. B: Matthew D. Ur an, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#5570324 If the response to Interrogatory 1 I is in the affirmative, state the amount of non-exempt funds on fV1 St MEMBERS 19 FEDERAL CREDIr UNION January 3, 2011 Danelle D O'Connor 4214 Apt D King George Drive Harrisburg Pa 17109 Account Number: XXX501 Name on Account: Danelle D O'Connor Savings: $8.76 -5.00 (Membership Fee;) $3.76 Supplemental Savings: $23.18 Money Management Savings: $30.00 Checking: $726.96 50.00 (Processing Fee) $676.96 Account Number: XXX208 Name on Account: Kids 1" Savings: Jaime A Quinones Danelle D O'Connor (Joint) $201.34 -5.00 (Membership Fee) $196.34 $300.00 Statutory Exemption was not taken out. 4LJod B urkholder Deposit Operations Analyst 5000 Louise Drive • P.O. Box 40 • Mechanicsburg, Pennsylvania 17055 • (800) 283-2328 0 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 Jody L. Burkholder (Name) Deposit Operations Analyst of Members 1 st 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. SIGNATURE) SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff tixttitr of ?arvptjr ?'t n " f.:'' ??.1 ?? Jody S Smith° Chief Deputy °C?il 1`?llC3 PM Richard W Stewart CL7UI?1 TJ Solicitor -W f17/3b"2 LA1J6 Pr`"Nl?s CL Uf! NxA 2iec Discover Bank vs. Case Number Danelle Dawn OConnor 2006-7168 SHERIFF'S RETURN OF SERVICE 01/03/2011 02:50 PM - Tim R. Black, Deputy Sheriff, who being duly sworn according to law, states that on January 3, 2011 at 1450 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Danelle Dawn OConnor, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1166 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Marisol Barber, Branch Manager, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on January 4, 2011 to Danelle D. OConnor, 162 Lincoln Street, Carlisle, PA 17013. 08/24/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $76.85 SO ANSWERS, 1 August 22, 2011 RON R ANDERSON, SHERIFF . ? > UCH Fd LL-- pty- 53a4-, ic; coumysi;[e jne0ff, f eie^"Soft !"::.