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HomeMy WebLinkAbout07-7251r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs CURTIS W MYERS BARBARA MYERS Defendants No: L - 7.2.g t /Il l 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 06191397 C A Pit CXC I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK I Plaintiff vs. Civil Action No s CURTIS W MYERS BARBARA MYERS Defendants 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 I - J COMPLAINT li 1. Plaintiff, is a corporation with offices at 6500 New Albany Rd, New Albany, OH 43054. 2. Defendants are adult individual(s) residing at the address listed below: CURTIS W MYERS 405 NEWVILLE RD NEWBURG, PA 17240 BARBARA MYERS 405 NEWVILLE RD NEWBURG, PA 17240 3. Defendants applied for and received a credit card issued by Plaintiff bearing the account number 6011002380079764 . A copy of t Plaintiff's Statement of Account s attached hereto, marked as Exhibit "A" and made a part hereof. 4. Defendants made use of said credit card and currently has a balance due and owing to Plaintiff, as of November 12, 2007 , in the amount of $3568.04 5. Defendants are in default by failing to make payments when due. 6. Plaintiff avers that the Agreement between the parties provides that Defendants will pay Plaintiff's attorneys' fees. J 7. Plaintiff avers that such attorneys' fees will amount to $500.00 . 1- 1 8. Although repeatedly requested to do so by Plaintiff, Defendants have willfully failed and/or refused to pay the balance due to 'a Plaintiff. Wherefore, the Plaintiff prays for Judgment in its favor and against Defendants , CURTIS W MYERS AND BARBARA MYERS JOINTLY AND SEVERALLY , in the amount of $3568.04 with interest at the legal rate of 6.000% per annum from date of judgment plus attorneys' fees of $500.00 , and costs. i i James C. rmbrodt,42524 WELT M., W INBERG & REIS CO., L.P.A. 436 Se en Avenue, Suite 2718 Pitts rg , PA 15219 (412) 43 FA X: 41 -33 -7955 8-7130 0619 39 C A Pit CXC This law firm is a debt collector attem ng to collect this debt for our client and any information obtaine ill be used for that purpose. EXHIBIT 18 SDSN6A01 0006078 CURTIS MYERS BARBARA MYERS 405 NEWVILLE RD NEWBURG PA 17240-9376 Make a payment now or schedule one in advance. It's fast, easy, secure - and freel Visit us today at Discovercard.com/payments ?Q I ! PO BOX 15251 ??lurl?nnnl?lu?nn??? =633, e-mail or telehone chaneg ppaa WILMINGTON DE 19886-5251 above, or go to Discovercard omBPrintiyourhe-mailnaddress to II1111111 receive important Account information and special offers. 000006011002380079764035680400000000042000 Discover More Card Account Summary Closing Date: July 18, 2007 CARD tnter Amount Enclosed Below Payment Due Date $ August 17, 2007 Please make check payable to Discover Card. Minimum payment due includes a past due amount of $342.00. Account number ending in Payment Due Date , Minimum Payment Due Credit Limit Credit Available Cash Credit Limit Cash Credit Available page 1 of 2 9764 Previous Balance $3 427 54 August 17, 2007 Payments And Credits , . 0 00 $420.00 Purchases + . 78 00 $2,900.00 Cash Advances + . 0 00 $0.00 Balance Transfers + . 0 00 $800.00 Finance Charges + . 62 50 $0.00 New Balance . $3,568.04 You may be able to avoid Periodic Finance Charges , see the reverse side for details. :Cashback Bonus® Opening Cashback Bonus Balance $ 3 46 New Cashback Bonus Earned . + 0,00 Cashback-Bonus® Anniversary Cashback Bonus Balance Avgilable to Redeem $ 3.46 Date: March 18 0.00 How Can We Help You? For Account Inquiries, write to us at. Please have your Discover Card available. Discover More Card, PO Box 30943 Salt Lake City UT 8,4130 Manage your account online at Discovsrcard com , . Customer Service: 1-800-DISCOVER (1-800-347-2683) Forr assistance, (Telecommunications se ? re a se sides for the D°a?: Transactions $0 Fraud Liability Guarantee Use our Di C d h Trans. Post y scover ar wit confidence. Date Date Other/Miscellaneous Jul 18 Jul 18 OVERLIMIT FEE 00 $ 39 Jul 18 Jul 18 LATE FEE ' 39.00 'Information For You While we are permitted under the Cardmember Agreement to increase the APRs on your Account because your payment was late, we have chosen not to do so at this time. We have terminated, however, any introductory or promotional rate on purchases and any special balance transfer rate, and applied the standard APR For purchases to your outstanding balance of purchases and balance transfers. -However-,-we reserve the right to increase the APRs on your Account if you fail to pay the minimum payment due by the payment due date. See the Default Rate Plan section of the Cardmember Agreement for details. * * * ATTENTION * * * Your account is seriously past due. Payment of the amount due and arrangements for future payments should be made immediately. Soon we'll no longer be printing your full account number on your statement. It's just another way to keep your information safe. But of course, if for any reason you need your full account number, it'll still be right there on your card. . . CARD ulaLtbEK tAccount number ending in 9764 Have a question? Talk to us. k ? t, There's no telling when you might have a question about your Account. Which is why we're here 24 hours a day, 7 days a week. Perhaps best of all, you'll be connected to one of our friendly, knowledgeable Customer Service ' Representatives in less than a minute. Real answers from real people. It's just one of the ways we put you first. Call us at 1-800-DISCOVER (1-800-347-2683). 02006 Dic ewk, M.mb., FDIC Closing Date: July 18, 2007 page 2 of 2 Finance Charge Summary Avers Daily Daily Average dic Nominal PP E NTAGE NNUAL PER ENTAGE Periodic Transaction Fee Ra tes A ES RATES AM RGES current billing period: 30 days C H CHA Purchases $2080.21 0.07121% UNKNOWN FCU DESC - STMCIM1.43 0.04381% 25.99% V 15 99% F 25.99% .41 none Cash Advances $0 0.07737% . 28.24% V 15.99% 28.24% $18 $18.09 $0 none The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above. $o Q i uest ons? Manage your account at Discovercard.com or call 1-800-DISCOVER (1-800-347-2683). 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 61, k o V11 t . 1A)'JI14ey1S (Name) Accounts Manager of DFS 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. ((IIv`?r (Si ature) WWR # 6191397 CURTIS W MYERS 6011002380079764 co w 4. N cw? n:71 C.k) CD ai. c„a !: a-171 ot,, CASE NO: 2007-07251 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS MYERS CURTIS W ET AL TIMOTHY REITZ Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MYERS CURTIS W DEFENDANT the at 1838:00 HOURS, on the 11th day of December , 2007 at 405 NEWVILLE ROAD NEWBURG, PA 17240 by handing to BARBARA MYERS ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 18.24 Affidavit .00 Surcharge 10.00 „ I21t ?07 .00 46.24 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 12/12/2007 WELTMAN WEINBERG REIS BY : l T .-?.i 7 Depurty Sheri A.D. SHERIFF'S RETURN - REGULAR w CASE NO: 2007-07251 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS MYERS CURTIS W ET AL TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon MYERS BARBARA the DEFENDANT , at 1838:00 HOURS, on the 11th day of December , 2007 at 405 NEWVILT,R RnAn NEWBURG, PA 17240 by handing to BARBARA MYERS 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 6.00 Service .00 Affidavit .00 Surcharge 10.00 .00 J;1// -7 16.00 Sworn and Subscibed to before me this day of So Answers: ?E v R. Thomas Kline 12/12/2007 WELTMAN WEINBERG REIS By: DenAty Sheri A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. CURTIS W MYERS BARBARA MYERS Defendants No. 07-7251 CIVIL TERM PRAECI.PE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOLCZAN, ESQUIRE PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06191397 Judgment Amount $ 4068.04 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. 07-7251 CIVIL TERM CURTIS W MYERS BARBARA MYERS Defendants PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendants, CURTIS W MYERS BARBARA MYERS above named, in the default of an Answer, in the amount of $4068.04 computed as follows: Amount claimed in Complaint $3568.04 Interest from date of judgment at the legal interest rate of 6% per annum Attorney's fees $500.00 TOTAL $4068.04 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: 4 WILLIAM T. MOL AN, ESQUIRE PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#061.91397 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`" Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendants is: 405 NEWVILLE RD NEWBURG,PA 17240 v IN THE COURT OF COMMON PLEAS CUMBERLAND COUN , CIVIL DIVISION DISCOVER BANK ' Plaintiff CURTIS W MYERS Defendant(s) IMPORTANT NOTICE TO: CURTIS W MYERS 405 NEWVILLE RD NEWBURG,PA 17240 Date of Notice: )--?IQ-Qv WWR## : 06191397 PENNSYLV IA Case # 0-l--7Z-51-ClVlL F- RM YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED O ENTER A 4 ITTEN 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 i PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HA 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 PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 {OFFICE MAY BE ABLE TO IMAY OFFER LEGAL NO FEE. BY : att-;?U/[Cwc, 4 WW7wvV-- PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15 19 IN THE COURT OF COMMON PLEAS CUMBERLAND CO Y, PENNSYLV? IA CIVIL DIVISION i I DISCOVER BANK Plaintiff BARBARA MYERS Defendant(s) IMPORTANT NOTICE TO: BARBARA MYERS 405 NEWVILLE RD NEWBURG,PA 17240 Date of Notice : 1' O O V WWR#: 06191397 Case # 0J- _] Z5 I -C11Y1 L TEW YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED ENTER A WPITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE INIWRITING 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 HAV A LAWYER, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWY R. 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. i LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 BY : 4 m-LA w+ c-4 L/0602r?- PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15;19 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Case no: 07-7251 CIVIL TERM Plaintiff VS. CURTIS W MYERS BARBARA MYERS Defendants NON-MILITARY AFFIDAVIT 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 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, CURTIS W MYERS BARBARA MYERS 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, CURTIS W MYERS BARBARA MYERS is not in the military service. Further Affiant sayeth naught. Z . AFFIA T SWORN TO AND SUBSCRIBED in my presence this day of S /?. N ARY PUBLI 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 Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 JAN-17-2008 11:52:44 -. Last Name First/Middle Begin Date Active Duty Status Service/Agency MYERS 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. 14 0 . it )6t lot 00*4, 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. §§ 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/faa/t)is/PC09SLDR.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 1/17/2008 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: MLXYGUAGNL https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 1/17/2008 Request for Military Status . Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 JAN-17-2008 11:53:04 '< Last Name First/Middle Begin Date Active Duty Status Service/Agency MYERS 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. §§ 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/faa/yis/PC09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmde.osd.mil/scra/owa/scra.prc_Select 1/17/2008 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:MLYBPDBQMX https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 1/17/2008 Z ? ? ? C."1i ^a <.? ? _ c:::? c7 ?.?7 R r ?: ? o0 0 ,. c? ? ?-? ? y _ D 1. ?{ ? 1 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. CURTIS W MYERS BARBARA MYERS Defendants CURTIS W MYERS BARBARA MYERS 405 NEWVILLE RD NEWBURG,PA 17240 Civil Action No. 07-7251 CIVIL TERM NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Jud gent was entered against you on al (xx) Assumpsit Judgment in the amount of $4068.04 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: PROTH NOTAR DEP Y) Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 70` Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. CURTIS W MYERS BARBARA MYERS Defendants No. 07-7251 CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C WARMBRODT PA I. D #42524 WELTMAN, WEINBERG & REIS CO., L.P.A./ 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06191397 I i I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 07-7251 CIVIL TERM CURTIS W MYERS BARBARA MYERS Defendants PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WELTMAN, WEINBERG & REIS CO., L.P.A. By: JAMES C W PA 1. D #425 4 WELTMA , WE 2718 Kop ers E 436 Sev nth Pittsbur h, P (412) 4 4-N55 Sworn to and su rit before me this day of Februa 08 i' NOTARY P LIC RODT ANBERG & REIS CO., L.P.A. ?ilding enue 15219 WWR #06191397 Wayne: M tdntary Public Ci City Of Pitts -i;egimny CourNy MY Commissl=' ?7 ,;,.?? .bane 29, 2010 Member. Pe- - ccQn of Notaries O r n -j J 0 LU ':f4 C-r