HomeMy WebLinkAbout08-1784IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE BANK USA, N.A. ((??
Plaintiff No: ?$ - 1194 l,ivil-F"
VS.
COMPLAINT IN CIVIL ACTION
THOMAS J SHORT
AKA THOMAS J SHORT II
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 1400
Pittsburgh, PA 15219
(412) 434-7955
FAX: 412-338-7130
06524644 C J Pit SJS
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE BANK USA, N.A.
Plaintiff
VS. Civil Action No
THOMAS J SHORT
AKA THOMAS J SHORT II
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
1. Plaintiff , CHASE BANK USA, N.A. is a corporation with
offices at 3700 WISEMAN BLVED, SAN ANTONIO, TX 78251
2. Defendant is an adult individual residing at 2397 LAMBS GAP
ROAD, ENOLA, PA 17025.
COUNT I - ACCOUNT NO. 4266841072240805
3. Defendant applied for and received a credit card issued by
Plaintiff bearing the account number 4266841072240805.
4. Defendant made use of said credit card and has a current
balance due of $7739.78.
5. Defendant is in default of the terms of the cardholder
Agreement having not made monthly payments to Plaintiff thereby
rendering the entire balance immediately due and payable.
6. Plaintiff avers that the Cardholder 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
Statement for account number: 4266 8410 7224 0805
' New Balance Payment Due Date Past Due Amount Minimum Payment
$7,739.75 12/10/07 $1,246.00 $3,294.78
Make your check payable to Chase Card Services.
Amount Enclosed $ New address ore-mail? Print on back.
426684107224080500329478007739780000007
31339 BEX Z 31907 C
THOMAS JSHORT
2397 LAMBS GAP RD
ENOLA PA 17025-1161
L1JIIrrrIIIrrrrrlrLlllrrrrllrrrlLllrrrrrlllllrrLrrIIL111
45000 L60 281: 203 LO 7 2 24080 SL llw
CARDMEMBER SERVICE
PO BOX 15153
WILMINGTON DE 19886-5153
Opening/Closing Date: 10/16/07 -11/15/07 CUSTOMER SERVICE
12/10/07
IfiffW STATES
D
D
Payment
ue
ate:
TAL SERME Minimum Payment Due: In U.S. 1-888-305-4016
$3,294.78 Espanol 1-888-446-3308
TDD 1-800-955-8060
Pay by phone 1-800-436-7958
Outside U.S. call tolled
1-302-594-8200
VISA ACCOUNT SUMMARY Account Number: 4266 841 0 7224 0805
ACCOUNT INQUIRIES
Previous Balance $7,507.22 Total Credit Line $6.000 P.O. Box 15298
Purchases, Cash, Debits +$39.00 Available Credit $0 Wilmington, DE 19850-5298
Finance Charges +$193.56 Cash Access Line $1,200
New Balance $7,739.78 Available for Cash $0 PAYMENT ADDRESS
P.O. Box 15153
Wilmington, DE 19886-5153
VISIT US AT:
www.chase.comlcreditcards
Its not too late to resolve the outstanding balance on your credit card account. We have a
variety of payment options that may be right for you. Call 1-888-792-7547 (tolled
1-302-594-8200) today.
TRANSACTIONS
Trans Amount
Date Reference Number Merchant Name or Transaction Description Credit Debit
11111 LATE FEE 39.00
FINANCE CHARGES
Finance Charge
Daily Periodic Rate Corresp. Average Daily Due To Transaction Accumulated FINANCE
Category. 31 days in cycle APR Balance Periodic Rate Fee Fin Charge CHARGES
Purchases V.08216% 29.99% $6,721.79 $171.21 $0.00 $0.00 $17121
Cash advances V .08216% 29.990/6 $0.00 $0.00 $0.00 $0.00 $0.00
Convenience check V .08216% 29.99% $278.71 $7.10 $0.00 $0.00 $7.10
Balance transfer V.082116% 29.99% $598.68 $15.25 $0.00 $0.00 $15.25
Total finance charges
$193.56
Effective Annual Percentage Rabe (APR): 29.99%
Please see Information About Your Account section for balance computation method, grace period, and other important information.
The Corresponding APR is the rate of interest you pay when you tarty a balance on any transaction category.
The Effective APR represents your total finance charges - including transaction fees
such as cash advance and balance transfer fees - expressed as a percentage.
EXHIBIT
CHASE O
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(o2)
This Statement is a Facsimile - Not an original
X 0000001 FISM335 C 3 000 N Z 15 07/11/15 Page 1 of 1 08268 MAMA 31339 31910000030003133901
Address Change Request
Please provide information below only if the address information on front is incorrect.
Street Address: ------------------
City: ------------------
State: --
Zip: ----- ----
Home Phone: --- --- ----
Work Phone: --- --- ----
E-mail Address: ------------------
L
Information About Your Account
Lost or Stolen Cards: Please report your lost or stolen card immediately by
calling the Customer Service number found on the front of your statement.
Advisors are always available to assist you. You can reach an Advisor by
pressing 0 after you enter your account number.
Crediting of Payments: For payments by regular U.S. mail, send at least
your minimum payment due to our post office box designated for payments
shown on this statement. Your payments by mail must comply with the
instructions on this statement, and must be made by check or money order,
payable in U.S. Dollars, and drawn on or payable through a U.S. fnandal
institution or the U.S. branch of a foreign financial Institution. Do not send
cash. Write your account number on your check or money order. Payments
must be accompanied by the payment coupon in the envelope provided with
our address visible through the envelope window; the envelope cannot
contain more than one payment or coupon; and there can be no staples,
paper clips, tape or correspondence included with your payment. If your
payment is in accordance with our payment instructions and is made
available to us on any day except December 25 by 1:00 p.m. local time at
our post office box designated for payments on this statement, we will credit
the payment to your account as of that day. If your payment is in accordance
with our payment instructions, but is made available to us after 1:00 p.m.
local time at our post office box designated for payments on this statement,
we will credit it to your account as of the next day. If you do not follow our
payment instructions or if your payment Is not sent by regular U.S. mail to
our post office box designated for payments, crackling of your payment may
be delayed for up to 5 days. Payments made electronically through our
automated telephone service, Customer Service advisors, or our web site
will be subject to any processing times disclosed for those payments.
Account Informations Reported to Credit Bureau: We may report
information about your account to credit bureaus. Late payments, missed
payments or other defaults on your account may be reflected in your credit
report. If you think we have reported inaccurate information to a credit
bureau, you may write to us at the Cardmember Service address listed on
your billing statement
Notice About EleA n In Check Conversion: When you provide a check as
payment You authorize us either to use information from your check to make
a one-time electronic fund transfer from your account or to process the
payment as a check transaction. When we use information from your check
to make an electronic fund transfer, funds may be withdrawn from your
account as soon as the same day we receive your payment, and you will not
receive your check back from your financial institution. Call the customer
service number on this statement if you have questions about electronic
check collection or do not want your payments collected electronically.
Conditional Payments: Any payment check or other form of payment that
you send us for less than the full balance due that is marked "paid in full" or
contains a similar notation, or that you otherwise tender in full satisfaction
of a disputed amount, mud be sent to Card Services, P.O. Box 15049,
Wilmington, DE 19850-5049. We reserve all our rights regarding these
payments (e.g., if it is determined there is no valid dispute or if any such
check is received at any other address, we may accept the check and you
will still owe any remaining balance). We may refuse to accept any such
payment by returning It to you, not cashing it or destroying it All other
payments thatyou make should be sent to the appropriate payment address.
Annul Renewal Notice: If your account has an annual fee, it will be billed
each year or in monthly installments, whether or not you use your account,
and you agree to pay it when billed. The annual fee is non-refundable unless
you notify us that you wish to dose your account within 30 days of the date
we mail your statement on which the annual fee is charged and at the same
time, you pay your outstanding balance in full. Your payment of the annual
fee does not affect our rights to close your account and to limit your right to
make transactions on your account If your account is closed by you or us,
we will continue to charge the annual fee until you pay your outstanding
balance in full and terminate your account relationship.
Expleation of Flan Charges: We calculate periodic finance charges,
using the applicable periodic rates shown on this statement, separately for
each feature (e.g., balance transfer/comeniencrA checks and cash advance
checks ("check transaction"), purchases, balance transfers, cash advances,
promotional balances or overdraft advances). These calculations may
combine different categories with the some daily periodic rates. If there is a
'V' next to a periodic rate on this statement, that ram may vary, and the
index and margin used to determine that rate and its corresponding APR are
described in your Cardmember Agreement, as amended. There Is a
minimum finance charge in any billing cyde in which you owe any periodic
finance charges, and a transaction finance charge for each balance transfer,
cash advance, or check transaction, in the amounts stated in your
Cardmember Agreement, as amended.
To get the daily balance for each day of the current billing cycle, we take the
beginning balance for each feature, add any new transactions or other debits
(including fees, unpaid finance charges and other charges), subtract any
payments or credits, and make other adjustments. Transactions are added
as of the transaction date, the beginning of the billing cycle in which they are
posted to your account, or a later date of our choice (except that check
transactions are added as of the date deposited by the payee or a later date
of our choice). Fees are added either on the date of a related transaction, the
date they are posted to your account, or the last day of the billing cycle. This
gives us that day's daily balance. A credit balance is treated as a balance of
zero. If a daily periodic rate applies to any feature, we multiply the daily
balance by the daily periodic rate to get your periodic finance charges for
that day. We then add these periodic finance charges to your daily balance
to get the beginning balance for the next day. (If more than one daily periodic
rate could apply based on the average daily balance, we will use the daily
periodic rate that applies for the average daily balance amount at the end of
the billing cycle to calculate the daily periodic finance charge each day.)
To get your total periodic finance charge for a billing cycle when a daily
periodic rate(s) applies, we add all of the daily periodic finance charges for all
features. To determine an average dally balance, we add your daily balances
and divide by the number of the days in the applicable billing cycle(s). If you
multiply the average daily balance for each feature by the applicable daily
periodic rate, and then multiply each of these results by the number of days
in the applicable billing cycle(s), and then add all of the results together, the
total will also equal the periodic finance charges for the billing cycle, except
for minorvariations due to rounding. To pet yourtotal periodic finance charge
for a billing cycle when a monthly periodic rate(s) applies, multiply the
average dailybalance for each feature by the applicable monthly periodic rate
and add the results together. The total will equal the periodic finance charges
for the billing cycle, except for minor variations due to rounding.
Grace Period (at lead 20 days):
We accrue periodic finance charges on a transaction, fee, or finance charge
from the date it is added to your daily balance until payment in full is
received on your account. However, we do not charge periodic finance
charges on new purchases billed during a billing cycle if we receive both
payment of your New Balance on your current statement by the date and
time your payment is due and also payment of your New Balance on your
previous statement by the date and time your payment was due. There is no
grace period for balance transfers, cash advances, check transactions, or
overdraft advances.
In addition, it then is a "Qualifying Promotional Financing" sections a
this sMereent, you will not incur periodic finance charges on any
Remaining Balance that appears in that section if you pay that balance in full
by the applicable Expiration Date. To avoid finance charges on new
purchases when your New Balance includes any Remaining Balance(s) in
the Qualifying Promotional Financing section, pay your full New Balance
minus the total of those Remaining Balance(s) by the date and time your
payment is due. However, If your statement shows that a minimum payment
is due, we must receive at least that minimum payment by the date and time
specified on your statement, even if your New Balance consists only of
Qualifying Promotional Financing balances.
Also, for some Qualifying Promotional Financing balances, periodic finance
charges accrue during the promotional period but are not added to your
account balance. Instead, they accumulate from billing cycle to billing cycle.
This Is referred to as "deferred interest" If a deferred interest Qualifying
Promotional Financing balance is not paid in full by the applicable Expiration
Date, the deferred finance charges will be added to your account as soon as
the first day after the Expiration Date. Fuller, if you default under the terms
of your Cardmember Agreement, the deferred finance charges will be added
to your account as soon as the date of default.
BILLING RIGHTS SUMMARY
In Cap d Errors or Questions About Year Mti: If you think your bill is
wrong, or if you need more information about a transaction on your bill, write
cardmember service on a separate shed at P.O. Box 15299 Wilmington, DE
19850-5299 as soon as possible. We must hear from you no later than 60
days after we sent you the first bill on which the error or problem appeared.
You can telephone us, but doing so will not preserve your rights.
In your letter, give us the following information.
• Your name and account number
• The dollar amount of the suspected error
• Describe the errorand explain, if you can, why you believe there is an error.
If you need more information, describe the item you are unsure about
You do not have to pay any amount in question while we are investigating,
but you are still obligated to pay the parts of your bill that are not in
question. While we investigate your question, we cannot report you as
delinquent or take action to collect the amount you question. If you have
authorized us to pay your credit card bill automatically from your savings or
checking account, you can stop the payment on any amount you think is
wrong. To stop the payment, your letter or call (using the Cardmember
Serviceaddress or telephone number shown on this statement) must reach
us at least three business days before the automatic payment is scheduled
to occur.
Special Rule for Credit Card Purchases: If you have a problem with the
quality of goads or services that you purchased with a credit card (excluding
purchases made with a check), and you have tried in good faith to correct
the problem with the merchant, you may not have to pay to remaining
amount due on the goods or services. You have this protection only when
the purchase price was more than 850 and the purchase was made in your
home state or within 100 miles of your mailing address. These limitations
do not apply if we own or operate the merchant, or if we mailed you the
advertisement for the property or services.
MA021207
Statement for account number: 4305 8778 1006 0389
New Balance Payment Due Dale Past Due Amount Minimum Payment
$3,057.09 12/15107 $629.00 $774.00
Make your check payable to Chase Card Services.
Amount Enclosed $ New address or e-mail? Print on back.
CHASE O
430587781006038900077400003057090000009
44017 BEX Z 32407 D
THOMASJSHORTII
2397 LAMBS GAP RD
ENOLA PA 17025-1161
Irrrlll?l,rlrrirl?rlr?ll?1r111r1r111?lrlrrrllr?lrlrrrllr?llrrl
I?nlllnrllln?ulrl?lrl?urllnrllrllunrlll?luln?lllnrl
CARDMEMBER SERVICE
PO BOX 15153
WILMINGTON DE 19886-5153
1:5000160281: 97478 L00603896tie
Openin'llosing late: 101117 - 11/20/07 CUSTOMER SERVICE
CHASE O
Minimum Payment Due: $774.00 Espahol 1-888.446-3308
TDD 1-800-955-8060
Pay by phone 1-800436-7958
Outside U.S. call collect
1-302-594-8200
VISA ACCOUNT SUMMARY Account Number: 4305 8778 1006 0389
ACCOUNT INQUIRIES
Previous Balance $2,941.98 Total Credit Line $3.100 P.O. Box 15298
Purchases, Cash, Debits +$39.00 Available Credit $42 Wilmington, DE 19850-5298
Finance Charges +$76.11 Cash Access Line $3,100
New Balance $3,057.09 Available for Cash $0 PAYMENT ADDRESS
P.O. Box 15153
Wilmington, DE 19886-5153
VISIT US AT:
www.chase.comicreditcards
IYs not too late to resolve the outstanding balance on your credit card account. We have a
variety of payment options that may be right for you. Call 1-888-792-7547 (collect
1-302-594-8200) today.
TRANSACTIONS
Trans Amount
Date Reference Number Merchant Name or Transaction Description Credit Debit
11/14 LATE FEE 9.00
FINANCE CHARGES
Finance Charge
Daily Periodic Rate Corresp. Average Daily Due To Transaction Accumulated FINANCE
Category 31 days in cycle APR Balance Periodic Rate Fee Fin Charge CHARGES
Purchases V .08216% 29.99% $539.14 $13.74 $0.00 $0.00 $13.74
Cash advances V .08216% 29.99% $1,029.21 $26.22 $0.00 $0.00 $26.22
Convenience check V .08216% 29.99% $1,418.99 $36.15 $0.00 $0.00 $36.15
Total finance charges
$76.11
Effective Annual Percentage Rate (APR): 29.99%
Please see Information About Your Account section for balance computation method, grace period, and other important information.
The Corresponding APR is the rate of interest you pay when you carry a balance on any transaction category.
The Effective APR represents your total finance charges - including transaction fees
such as cash advance and balance transfer fees - expressed as a percentage.
)P/ 2
EXHIBIT
This Statement is a Facsimile - Not an original
X 0000001 FIS33335 D 10 000 N Z 20 07/11/20 Page 1 of 1 05686 MA MA 44017 32410000100004401701
Address Change Request
Please provide information below only if the address information on front is incorrect.
Street Address: -----------_
City ------------
State: --
Zip: ----- ----
Home Phone: --- --- ----
Work Phone: --- --- ----
E-mail Address: ------------
-1
L
Information About Your Account
Lod or Stolen Cards: Please report your lost or stolen card immediately by
calling the Customer Service number found on the front of your statement.
Advisors are always available to assist you. You can reach an Advisor by
pressing 0 after you enter your account number.
Crediting of Payments: For payments by regular U.S. mail, send at least
your minimum payment due to our post office box designated for payments
shown on this statement. Your payments by mail must comply with the
instructions on this statement, and must be made by check or money order,
payable in U.S. Dollars, and drawn on or payable through a U.S. financial
institution or the U.S. branch of a foreign financial institution. Do not send
cash. Write your account number on your check or money order. Payments
must be accompanied by the payment coupon in the envelope provided with
our address visible through the envelope window; the envelope cannot
contain more than one payment or coupon; and there can be no staples,
paper clips, tape or correspondence included with your payment. If your
payment is in accordance with our payment instructions and is made
available to us on any day except December 25 by 1:00 p.m. local time at
our post office box designated for payments on this statement, we will credit
the payment to your account as of that day. If your payment is in accordance
with our payment instructions, but is made available to us after 1:00 p.m.
local time at our post office box designated for payments on this statement
we will credit it to your account as of the next day. If you do not follow our
payment instructions or if your payment is not sent by regular U.S. mail to
our post office box designated for payments, crediting of your payment may
be delayed for up to 5 days. Payments made electronically through our
automated telephone service, Customer Service advisors, or our web site
will be subject to any processing times disclosed for those payments.
Account Information Reported to Credit Bureaus: We may report
information about your account to credit bureaus. Late payments, missed
payments or other defaults on your account may be reflected in your credit
report. If you think we have reported inaccurate information to a credit
bureau, you may write to us at the Cardmember Service address listed on
your billing statement.
Notice Ahead Electra', Cheek Comenioa: When you provide a check as
payment, you authorize us either to use information from your check to make
a one-time electronic fund transfer from your account or to process the
payment as a check transaction. When we use information from your check
to make an electronic fund transfer, funds may be withdrawn from your
account as soon as the same day we receive your payment and you will not
receive your check back from your financial institution. Call the customer
service number on this statement if you have questions about electronic
check collection or do not want your payments collected electronically.
Coedidesal Payments: Any payment check or other form of payment that
you send us for less than the full balance due that is marked "paid in full" or
contains a similar notation, or that you otherwise tender in full satisfaction
of a disputed amount must be sent to Card Services, P.O. Box 15049,
Wilmington, DE 19850-5049. We reserve all our rights regarding these
payments (e.g., if it is determined there is no valid dispute or if any such
check is received at any other address, we may accept the check and you
will dill owe any remaining balance). We may refuse to accept any such
payment by retuming it to you, not cashing it or destroying It All other
payments that you make should be sentto the appropriate payment address.
Annual Reasual NeNcs: If your account has an annual fee, it will be billed
each year or in monthly installments, whether or not you use your account,
and you agree to pay it when billed. The annual fee is non-refundable unless
you notify us that you wish to close your account within 30 clays of the date
we mail your statement on which the annual fee is charged and at the same
time, you pay your outstanding balance in lull. Your payment of the annual
fee does not affect our rights to close your account and to limit your night to
make transactions on your account If your account is closed by you or us,
we will continue to charge the annual fee until you pay your outstanding
balance in full and terminate your account relationship.
Explanation of Finance Chaves: We calculate periodic finance charges,
using the applicable periodic rates shown on this statement, separately for
each feature (e.g., balance transfer/convenience checks and cash advance
checks ("check transaction"), purchases, balance transfers, cash advances,
promotional balances or overdraft advances). These calculations may
combine different categories with the same dally periodic rates. If there is a
V next to a periodic rate on this statement, that rate may vary, and the
index and margin used to determine that rate and Its corresponding APR are
described in your Cardmember Agreement, as amended. There is a
minimum finance charge in any billing cycle in which you owe any periodic
finance charges, and a transaction finance charge for each balance transfer,
cash advance, or check transaction, in the amounts stated in your
Cardmember Agreement as amended.
To gat the daily balance for each day of the current billing cycle, we take the
beginning balance for each feature, add any new transactions or other debits
(including fees, unpaid finance charges and other charges), subtract any
payments or credits, and make other adjustments. Transactions are added
as of the transaction date, the beginning of the billing cycle in which they are
posted to your account, or a later date of our choice (except that check
transactions are added as of the date deposited by the payee or a later date
of our choice). Fees are added either on the date of a related transaction, the
date they are posted to your account, or the last day of the billing cycle. This
gives us that days daily balance. A credit balance is treated as a balance of
zero. If a daily periodic rate applies to any feature, we multiply the daily
balance by the daily periodic rate to get your periodic finance charges for
that day. We then add these periodic finance charges to your daily balance
to get the beginning balance for the next day. (if more than one daily periodic
rate could apply based on the average daily balance, we will use the daily
periodic rate that applies for the average daily balance amount at the end of
the billing cycle to calculate the daily periodic finance charge each day.)
To got your total periodic finance charge for a billing cycle when a daily
periodic rate(s) applies, we add all of the daily periodic finance charges for all
features. To determine an average daily balance, we add your daily balances
and divide by the number of the days in the applicable billing cycle(s). If you
multiply the average daily balance for each feature by the applicable daily
periodic rate, and then multiply each of these results by the number of days
in the applicable billing cycle(s), and then add all of the results together, the
total will also equal the periodic finance charges for the billing cycle, except
for min(Irvariations duets rounding. To getyourtotal periodicfini nce charge
for a billing cycle when a monthly periodic rate(s) applies, multiply the
average daily balance for each feature by the applicable monthly periodic rate
and add the results together. The total will equal the periodic finance charges
for the billing cycle, except for minor variations due to rounding.
Grace Period (al lead 20 days):
We accrue periodic finance charges on a transaction, fee, or finance charge
from the date it is added to your daily balance until payment in full is
received on your account. However, we do not charge periodic finance
charges on new purchases billed during a billing cycle if we receive both
payment of your New Balance on your current statement by the date and
time your payment is due and also payment of your New Balance on your
previous statement by the date and time your payment was due. There is no
grace period for balance transfers, cash advances, check transactions, or
overdraft advances.
M addition, if there is a "Oaalifying Promotional Financing" section on
this slatemeaR you will not incur periodic finance charges on any
Remaining Balance that appears in that section t you pay that balance in full
by the applicable Expiration Date. To avoid finance charges on new
purchases when your New Balance includes any Remaining Balance(s) in
the Qualifying Promotonal Financing section, pay your full New Balance
minus the total of those Remaining Balance(s) by the date and time your
payment is due. However, if your statement shows that a minimum payment
is due, we mud receive at least that minimum payment by the date and time
specified on your statement, even if your New Balance consists only of
Qualifying Promotional Financing balances.
Also, for some Qualifying Promotional Financing balances, periodic finance
charges accrue during the promotional period but are not added to your
account balance. Instead, they accumulate from billing cycle to billing cycle.
This is referred to as "deferred interest" If a deferred interest Qualifying
Promotional Financing balance is not paid in full by the applicable Expiration
Date, the deferred finance charges will be added to your account as soon as
One first day after the Expiration Date. Further, if you default under the terms
of your Cardmember Agreement the deferred finance charges will be added
to your account as soon as the date of default.
BIWNG RIGHTS SUMMITRY
Is Cue of Efrers or Qaestioc Akeal Your Bill: If you drunk your bill is
wrong, or if you need more information about a transaction on your bill, write
Cardmember Service on a separate sheet at P.O. Box 15299 Wilmington, DE
19650-5299 as soon as possible. We mud hear from you no later than 60
days after we sent you the first bill on which the error or problem appeared.
You can telephone us, but doing so will not preserve your rights.
In your letter, give us the following information.
• Your name and account number
• The dollar amount of the suspected error
• Describe the enrorand explain, if you can, why you believe there is an error.
If you need more information, describe the item you are unsure about
You do not have to pay any amount in question while we are investigafing,
but you are still obligated to pay the parts of your bill that are not in
question. While we investigate your question, we cannot report you as
delinquent or take action to collect the amount you question. If you have
authorized us to pay your credit card bill automatically from your savings or
checking account you can stop the payment on arry amount you think is
wrong. To stop the payment, your letter or call (using the Cardmember
Service address or telephone number shown on thLq statement) mud reach
us at lead three business days before the automatic payment is scheduled
to occur.
Special Rub fair Credit Card Purchases: If you have a problem with the
quality of goods or services that you purchased with a credit card (excluding
purchases made with a check), and you have tried in good faith to correct
the problem with the merchant, you may not have to pay the remaining
amount due on the goads or services. You have this protection only when
the purchase price was more than $50 and the purchase was made in your
home state or within 100 miles of your mailing address. These limitations
do not apply if we own or operate the merchant, or if we mailed you the
advertisement for the property or services.
MA021207
CMX17a'75
t;ardrnember Agreement MREEM WA ENT vah as rdweOCed sa the Card rr
Tt:s?P? ? ddb a of rctaratis up bro
o M p"
arris
w"Ibal *no ft. a rc oeat. .6
. se re, im p> BID forgo ;lease read siseL acc far WYleg
foraredclrerPaTveracr?mtYevr wv"mirldvdit:braPei?'
IfaY es {or dtrwa ucb d TaU. together byd oW a r110e 0
ttue'i¦ ¦ 4°'00168 ¦esDamt is Wad ?- s it Yon wg7(ba arcs it
phase*aroback dbyl ??eY","MLYanwi to and
attrs o,alo ?Ysurrad•WbassficrlDO D adthbr30drya 1°ceiringt act Yv oat urea Yom du wa+dj .wjj Thn
OC mad W 008
wrrde'Yuf .,Y esd By ?ePPked 'so
Throngf>ew tldc rgre st+d accesed amaat,incbgag?om as "a is ally ra SW the icsar dYetlr facapp?ing ? address Wool sva arravre cm*
for 00 eccves+l endvdp U? a the acuuvst fiU owl ? P ago a Fmk YOU
eennalnumb
srraWOapeef cock as,
Or otireraccsss USING H6 Yom agnsmaet p,ROSSI, ball?f[ er?
to em secomd nod sbodd be bead live{na be raspaspO1
A
Yvnr?sccadasot
4 is ace Gass occoget you
1, 1 siegesMwdisrcedk? Vilpfirld
mat Bad ho P lwvzld=adbwMd batatnsmetbatYee
i v as was Mssmtowtes?°nd rPe star
? eD t°s
use your far pals Van"
G=am yn t VsrseclMr. e?ae A k is cot p
.Yp°c vnYew Ca&ad"Ups? ntl°isau?>rrrvte US I
GEnsdra ypfs raY te9Mbet4h dsa relay m rhea to ??SlUY?Vr ?
Maim
babsclis Yu s' Lek M Bing dockc in
ea nr not nsi lbw ti°a? D* lbb
anrvaYaces va dbA you maYa d am of ¦ra edrsw checks
.r for Wear Erore a r
OLMS a¦ tba Eck wT ti'a m igued ar baEst CbU& pR¦ur 'Ohm a name ac and isho I>w xs Wifs 0 YLUB 1% kr
treated It coo yes d b thk amold ebf trarvfw fiv"m?
ll cb "yto ce &n? IEotwil judk d u Yan ma rue
rates 'rid ,g..dcxShl
*AVM ed ? ? ba treated ar cash adrarrcac r er a ntMsr
foclwsM'd'?c
and has vWW W babPwc Moro a" ccooe rssrs afloat
Salsoca' earl-rmnle l see w of oft good eC ? mar rrl assail
keening tistk d Year sccsord balenca. Including your eoesraltbebea is vWrYoa aadh
of nur rrtdated cwvPep1w.r a Pewvn d aparrwdet bobace troushr ap to Tom
scalable credit. TM we may process
mesbm
cash troor erfaards tans[ is Vg Gub YodvMYetLYDef j cardler °? xbeblsiefatyoU
Dorm no .,tmckvagvrrW
W roasted
. rottAdreW,x I TO horn an aggr aid[ bank to
and At to UK CIVICH" Iceland: Our
ae"
trraa d tHs tiro
braks. Yea M a that chaDlnn9 ° ep9A< Under 1101
cores se c"'Aagtsamant deridedweiWWp°& d<csOd' vw? u1'n
Bfitfe0 bllrmcy.bb-P rw qdg t rviUa the ?Mtl NI&YW haw
,Ydd• a Nfing Sol, a
,coma your . not *M 1:
's be" 1Y}nrtbw or
qtb eabvd¦r uwstb
bs
CTde sutdleg ¦ "o
1,Rdboorissyclsaaw . so bosoms
stars Yoe sModd thins to 1 Partve b Oss tire aCCjcsead ell you
02"L 7W W=Wsz YOW
utltvttited scar becw ie yid 1?r wcemd sodDDa'bn t
o ? p It
Yea SeAI assordag tf Ga farms sl tb s ag
atxvtuR aceourtt toady fry ns•t d Yme acorn
Pa*g °g ??o advasl card for use bf esrrt
s of d4 "do:00C zVor
UP eu r.°t my SPM~ on the areas report Peie H M year =ccamt
do $a., no* tea tU ty appe a an stdbvrivd users d cardsvrkh a ditlers
IniT CfaA ?Dt9D ; deslty? anY Lards. checks or arty Dd1
nv++,?l?? Year s?? ? cum 1100hed war
that era ?s?et Am, tfi
accova, ,no s setstin Yves
F ? ? a s? a $ fink his eM ? YWon our bung Aewei°el dsd ?dttTin
e ?tgna ma ba Dead ht rosbaad p°,,U 'bb l
CRA a&w a ZOe?, eta chrrgsd agabnt!M to credit gna. Toll are r s a
and is rtihm ,nsecdese jr, thugad agamst Ya teas and rRanw cbem
mal?eg svret see ? t,.? v You on hriu+it the e= descsi? ? orvi-IOL
? .T My gas Wainniortwt imp te agpaa Yav PsetYyPeslmie'dutallriorsestyonto
pe usawieene? bslaawowryewetsdkgneCMwwbap„rats
71de egf te1aef UPl" ??sesv, tadtrcay ar cnrce) Yanr ? as not to do ar. NM
PawPlystor n a Wis. uivdkFns t? sti°d yaR obig¦tioo
Wil ptyaeseilaar Tadrr?a arlf transedee Ada You vandba d Vlmw bderaatiood0 Uaw suan IS Am I V
I it, I¦ ? 95 ad Mdereadead? km- W3 0envtn 7besbe f>e rate sscb
6.4mid or mom convf
doMa3nlfit1eararw t1rt??-u ?a ihv Tap of retch
OM W MS e dv eWmm MMs bix f¦? spiv ? h=????ihr
SndtY
nap r b1a
is my _? yD.ear OW nu dig eebfc taocestdeY date 7lrs ra herd
?j?vuvarawe*P-w 0e door invylosrt the r.te oa h;par esrdl1d flu
card vi
of act" We ?l do, Ma? ??9M an atprrt addifilm of oegov risstireBud to ?U-L s d°"kr
of riles Brads b sondret txrrramcy Bud ccpft" ad to y
600 us S Sr>t be cast rda re 1130 IL S madman
made in U
iWo'cud in L W wsr. ise tuoeers and charges mrY et+PlY % eoykda
thaasdr es4?t se
n. dsc6aa r traDtac4sa
c6sois pcarad rmc We "T bul era na1 ragt*ad
Eelvcaf unrYoltb¦ tvtfeadap Isssoac
en yow act?__,.??,d 6COMWoODU.
• bacwa d b y, dsWWk ac,vly n6
.lactwlaw moofaerbd
. Pl eyed 7 Dlhee ts+n of, account is declined lot
s
' (vt eaY losses H a trsnsacl3oa I a.d'd W falzbls.
l? am d tz: by atM6iP?dM *,st Tor IN DOW Yaw C nY??Yoe we MY to
pot elate frvese ? sebd We wi soft YOU vnss 1?e
sud.atwa- s 0 ty decline Yew au?1ea Uensae4ora net tar isads V116? r+a teuh'a
R Eetb Allkkl Y"f k Y tv d tide Wbg*er to ettbrssua thtt
fur t vra sacl repo bpd rolum unpaid a dock Ex anY rarsD0.
dr ??Wtesrilyd!npotte?
azc.adad.vrrmold
b>cled? tblirlbora4 a aias Ts the imYea on 00 ebnL
' ,,? s(Yanraadltgnvhasboon
be ? I, Y s Past-"ed d'ack it Ps1d. rvs+dimg b =vvtbu c6s:t hs'utD
. Tfs cbe sect" ' ` e am trot raa ? dtnd Da it
reread et
9.44 k aMsr for
(,W ban forwetAdber We P-W 'he ' Na^Ycold.rOAheck. A a ' a
Cost ar SMre Checks r or=scant a 1r>ri W* vas at oaa a by wig dte
Waor now
Yv =on ¦ Do Pal
meY w d"a ?rtasde'YMN s4 a eccovntwnoAdr+rPoYsearr tar"iftow u ?r>o yr nroainda° v a rsbud to Your
nep"In YOU -* Us
OtaditpetrielRs eu., 4 f.t a x! it'll t" :
_ ed w d ,--
atcrom fat ieii a dace a i?b Vte than
you insf 550DD of such v1V10561100011 ?end ? w bowk betYd rill trot bs eAaslbas mods altar YON no* us of tlr k ?? or
wM on 10 i my sash »? ideadT for
Yd wydD?u¦ltoni+ren as dry nnrnthvr*aad chaos
,ss.nvere4lo
w
sobevr9t ArloatvbUlp, iadctArr nnecoto weh o vv. h ow
PROMW
? aednros in w
ereY afat•Rife YDe u to moo [rah eeRaia ptv
M. rtms>iYattisw mPstrymp amabpe urcladr
Ot? pe b?vcal-ad e r-' ylmx 9 staUnlevrswsd ards ¦Pd and scwsale forth tt+e d¦U =nd timr by
melee thopnamot p""" U 5.
in U S dollars drewevtfundt otr de ant
rnMltb tyre w®reCe1re on
e Tae e/m1eP S.brse?s of a foroiga Tn°acW bra s anch
ad vi SrwsatDmleBda6iid Bet ratrw7be vdaEmble Credit m
P!Tvm°u sa tod arag¦la rdi may not ?
c Ir
r eda ? snw Yve+PsYet-
r b,= shop 0- 114
tr
o?rwise:aPds?
°r tasturadiorgti ?d°f lsr+i "sreeelwhkbytr stud foes Gv
AMP ? ?c,dio_lw er ridb ei tips ? bs sold to us at Ua
0111
..o ?tpvlsd
'aelaea qv
o,' Ira mouthli stetevrenl Ws no ad aft Pte rig t
ds
fl addeaesistvd vnYe 1L is v nod then Wise no ad dsPeSe or f
e?°n t Pgs'ntt for esaapbL dtass M may accept the p"10901 and yin
of euy?pnyvwdatsreelvs bolaance We a?, re?uso to accept a antS,r
s that y-mek
WX so Brae m! i r aWn i te by doWDYmg It A l Other P Ut stetemants
reberd I fp dye rognbr p",d address shown as your ntondrOt tucks. rf lfrt
sbudd r9 to de ,.ob gt safest YON Amy PsYmeur clortis drrwr
or wsatdnanl from rho bank receurt oo S to t
e era res?e YrvP
pr0fad ad VOL, sepat7eent checks 8 YDrtrruthDdtation 1,,,S to ogeasha emrmd t
°d Over race" EXHIBIT
iwee? ^Dw blfml rids for With Formals f•sase dpe9at bovil
tmt
oaicalt o; l a•adrd. by d tbeeccbt°Wck A bank Doc" aot
staft mww? slooff
PeYmip1 40ty "? , C,b. tsd dorW" Eby u took your book seeamd miry
aaall
r 11 for rhrc4 rooft and eccoadnumbeR 70 d The 000alP "0At Tablr.
be 1101511 es aer1Y es the same dry we mo?ba eor records
and as Lamle t3ri doe. es tlmw0 11 fd}airaate tp°°dYOOtf,rajb?wryraacd00 bY ad (me hadlratsu0?Y011 1
as your blfol stetsw0ed. PDYmrd de s sad mr/ P0Y Charles. fife 1
VW nW pay more dam 11111 ViAme" k
to 6011:4 V" u ?. I yes b bang cbor9et bsCausv finance charges
at say ]a t 70tl WY lea 001 dtv>1 P0Y said ym e*ft balance 190
szw= on Y,W W" Aftmed allows YOOr WOV AW Wasp 14
It Ilea B°ferwe o st lets. Yew
-new Satsncr ?s do ,a bs the Nam Bdeaca. Dd A. it aa be dm krDOtt Of
E Mtrw Bebacd artba eus 11% of the New ti app
re;$I$r d???m? and any filled Is ? ? am
i a, 60 141M VW nptrar yourA? m we aamm au Od to d as For M
You agree I m for r ar.Fer 00*k Iturb
Md Credits in ek food by and credits s babttcsc VA* bwarAPRs
autba?0 to bdopn ? With whiff a at aoY dam we amY
as P'o" ., ? ¦ nt00d I a ? d cow chatpesatass billed my request sd? sgwyn tad &nf tram ale bits bythe maowt
to sutamadcalt rharpe yaw
Oi bMac you may e utforks ? W rharyes. mrmbetsuips
W4 it • .,Uri for ApaalUeaaadlottt 0d airy
o"Ot
PrOR&Ot t b DAr lea o'? of 15
beat Cbme ss• yae eta rsep ?npse. brut an r?r?"= ? a rcraunt
d qT accovat sr mss 1bvI Y0a
You le lea61AOduemtt d We
srcmuR yo
myrobal Miry offer speel haw loaftbsYvabsbuSe t
SI ° ? YN I Ck rite term d I* apsamont at awdiffed by '
Any PMMWO is offal: eda00 rates
PT i;,?Olnntl kIMANCE ?M ai P?OdOta gtr ywr to ? pm_r, ad 311css
Do* Perfalb; Bides s do sad Am" al periodic revs 6" ? °d TV Do Ike
I b
of tbic dosvntu0l Or prmedOd Pam s? yta fall
7abis that If at Ike the APR by 3d, and ® mew a va;5
PlIBCofc rate we ?s, dedsd Point s=COtmtmayvWvvA ehanour
Afolftboloppil
Variable AdmOmOrmO bole as as APR UVOL VIM' "'k daeafias is du prim0
ave APR U1s is The
m flee Prime now h ,Y eddin9 a mmDb' p for Prp Bate
we cidCUW to ??ap
1 ittew bet 0 d°}? PS I ? Aav p btd In Oil b r0y
Sta Tim -PAW BOB' is do
am ent
R des dWwitlarvativyrtrrlfffirsPVern dtrda yswan your
nfslmtc0
A cetife0 wa vA sdrei asMW
Herataftlltto0rb Oraw?ety dm Ptim0dm1 treldey, n1° Reps and
A `rarrpia',r, 0d is not r rrsak ? Kato lists ih° m ? ? we "ambyt
ftes?T sstbte° M? _a talc; B m, doff pari0i all and crnresP°odM
vm? tuIwo
each nriobN rep end ' atfnbltw0 i>•ts sbeatelargo WON t Prbe11 Rau 10.9%
old
dtbu>an%W"b?wa de0a COMM aP t odd doseebo"
the ApB.Tbe daftPadv& nu 8 nka dol P ? rata fromthe prarlrtsb!Wv
tesdKta s chens0 is a IA do ROW ntr we apple as of tM first
tc!yr° t calculation 1'r Cie bRhat ?Ob60, ialendrr amrda I. whkb we mrrrod1111111
.
day d CM rats bcrearrir rv.N b aere?r? s mow pa
new durya ad ? u Pey a b l y P ?rso
j)d"" ? Yttrr APRs ohs t0°y r°ry l 7oa are IN dslrud co undst dikes lot am Of
the &WyglbK l?rd you hen with w m any d our retau mom P m any
other
. }lee do art rovefre, for But 110Y1°set the is wool m dd a by the dote and lima
a==ttl or two wig 0r. st hest the midmOre palms
Yowl otccesd your ue 10 as tlut stet hux"d by tpeb?se a clasod,we dsmaad pays" f tluria?Ne r8o d by7eRa of and 1,813=1 and we do not o=aks 11070'11111
yaw
pp of yOpr e111st adonal we s ?e rime
PeCly' dtu APRs lbrclodOta °ay?°
11b s? tome events o=enrs, wu may asaamndthedulDuk
arsrdnl adyaacesl OP to a m
mvr°°L° wider the iotbrvlnl factors to
,apes tin et In The silt andal s adme yaw account has been opaty the
rate stated d11tmttaw year Msoft rate: Thefaogtb WD. atr7 your sccwat:,p10r shoos
,,jd,,ca,s0rbttsa? sad ikadnlal 11sduf aatyw yqa other 11110110=1111135
o! boar areourd' o relatedd conies; and WoMadun wr 0"" from coasomat
Of of
civa repoa? dpimad from Credit boresw The data rs rail VAN 1 lake appf7Io Ourchese
vah
the fast oat' al the bNIP11 cyclefn which the defouh arcars:w 11ta r:7 P
fug- i ?1
l ype eEe0itblyd APp sew 0"o drew it s deboks i11ra dD
.crew* ress i aP W tM madetaen d•Is R aimd »w?e detea t
loctitm ves ?° ees ? u ?tpe redaerd defeok reNr ar rsiastste
wa pYftsee. iko"d0a
at rd.eNd bsbauc 00 Vela a sfeLda.e0>?
a.a+n+ielslsahmsr.r .ea.?badtbel0dlnlyd°'"
sod sack ' 7Nt I. low k
semrd0 peri0dfvtas°
asetideseee?.w __?,
VVaetdwletetiepri0dk fltmtor cbsr00 b ° dWbOlw-bY dis do*
Fkd. d alts idt8ntt cy we to N* 00 AMY bdow
Iowa syfe a0ti
Siae?iLlorteai by
a Wvr Bdslce
iet W,r>deCesdP fa that if w•nv by atik CIO,
on sad tbee up miatereOP?Y+ 1°61
vw i e?aeteiir0(edtt °°d byda dvaot•
of pL Patdu?c sM prD°'atisrafl .01
K •
We rated* ti! rb.. vartsfar
nutitaes?ut? Ch, PVSooft, behac• trsssbtsi bdmca adeam woulo
we cdcdr_ > ?,adesa? ? euN
by P011 ,4for USPD1
409K Applus am Oak abyrO br s rdakodrawasdfi?•sfaawirtkOd
of err refuted hrkc-Y1a tal0tdate to
t died3ak a U°rs, brtu?tc?.. Owl" do" fm so woo w r
fighm
ecks "Noct to a imm ' -
?0sk a e.L . a ch
butdww ism--kg ? dey for ncb =wporr
Tr l++i bxdretds? fees. atbur sad debit
we Diet ffWe add k rr prd*?advance.
a of a
bsseierIt 0oatdrdtale ds? jNa W avoteetreba aCethe=k
Cwt a of our
tOO ?ds{it ebsck a ?POd°d by Pay' of
Vis ?ddygbdaacadratentiny that def?? B*AMMU that
ipo"Sted at
yob sad
. ii !?db b j: a a baswo of firs far ?o am t deF To add the Mir Culp 7opt tisbelTted" %,I,= for •sz? r f flees tins ds3fY patwdie rep
sbsl0 to 111 dip bared an the
etdeiis `° tlm rrAe far the satr?t?tORpY tale 4 Os
C°eM q!?° - dolt b*t bgmlw%va "d W ib?g Pb cdra ..lame
,,Mdse' m bwww sm°tad ul tM end d eema d pis for daily
dnlY !n"'? Stamp abrel° Oak doY Tide aY
caspnsBei°d ia? cbffvw tar the bam cycle, tap odd mg d the dirty choP Te ?ittrdl> )
% y y doft 00 Bp o ? rthe ?dti
ibdic each al.lfoeY far each da
P ??ffosmes ebsripm05 l? , ddu t.vawieherv Ptwvb" Y" a,
1dw say Parfodle ruled Is the Rotes coal Fssr Table . n k
1"dttnghlelwe Pe$sdlo,,I,momt0 msb *, airy ? cbstpe,rv0
???adi? ? ignrdrb?d uft dw SON iro da tyd' d the
f
wmV e to e?Wded alaerva mvInd by
Tbs taYSYe r90f idar 00
Foreic4e?/07N°by mom a yod•R1 wititic ?txt d ? P hus°s
1K eas 10 aeietr F= fa flee bpfmy vyda i a es. do srnslo d*bdbtoo lartborr
fw preri0ac firm! vials ° do ttvera ff0 duly balance for
?ttsa10al0t°dtb°LtvtntY?ptar,sdlbydtoatatbsr
pwd+sR dsAypotledre clterpsfair gist
d itF? vii' i ?'? s?opt br °?ir+or»Tist>oes ie° t° os
bdneeB'dad c
6nuanodomdAet liesls cy?eerxusped?Yee ve,bOfsass
tes ?eryrirtaadiedsu kk edttod ti)c
aasttsidift"16trbatet wYOe?cssdl8tnrereGrn we?melveepayment
eaiplf?leM k 11111:0110d Mhd daunt a bf1 n cyde fs dos sad ws
ePns'"perant 8.w rwe airitstma
_.we p s W
01, ym BBB sB y ?Pr' riivix
d?eu ?sd?=, obabntevansiers, bebtles a>mir cfiscls, c11sb
aPPRcsbis
sdreeeOR.?i adrsrrto at averdran adven=0r, l
for Coo Adraat0= We may charge you s Cas4 rtivve11nsactions:
TreOVIrek b Ib, paps and Fee: Table for each of the fonvMM
. cg*,§, w cbackt:
. carbei•wa
DUO!. 01
is dos p,tstMd bsbecad ? ??e you Is ply the
_ to take a Pay-" - yea bw-IF ad drr
to 001161 0 "a age ° mend t hi secegoal W. raey ors J agord O log 10 the
S,rvip chargss the PaYra'd to D t hit
too
peYm"t `berges Ws mWgo lg"""bdtata br dui Its There relay c6mt loss ere m d o For '. r mass
calopon at vi gu asrts,dimr dd?id ? 01 till W IN advance Wagon 1
let a cash adv bs I a to Wa am 01w" you a belong, lroarlss Its In
cilaar I
the B-1-1 end Fans TabN for each of for IoBowin9u"s'
Iessmtdw Fee, stated1D oubmtoc
• balsars trowdor drsckG
• bstaata ?Basnmabaroosw,add dottFo bsteNrlb u"atim
a we, cutago7 a' o1 ??etvid be be yow b0boc, [rata hr b o
tae tar a balance = d dates tsw,re Bsudin dot Bates and
Dygo f&
WAR
hoof tg loos The aawaas aada WV tb bWmY
Fe, bhauisrP•rcbasee kelbobWrd
WcbVi .Abaaddsdlvdub
pp?ol V"bws P Fee B Y?t? 1 u slag is tl 1NtK
?my?s•r ? s?0o°t?? m?1M?1e?do>xtn? m 3t1 woodwombill Na is
p°Pr
fail d ,i dt,dde wi nttd Y'us b0n yo'ar Watal,os aA volt
,typg blew u our
ch,rg•d old ? uwth,a y? P'tr8 co Sim" yoar,ct?asl Of mwm
the annual say ? al actutmt 11 ywe sccoatl is `hoed by 1" bsl,aDe
s torus {wrath ys' p,yyarratdtasdisB
=4
right en
lam( ys eytrarewrrt nts d adoi ,m pegmard by Ow data ord
e
tna Fee P cos an act neaitn u hest do ngdrs l(dM m t bisrd Owl , bOUaq We ntiw w,
,],,a ItN dus as strode a" Y ?? s T?ilk Itto wk drat
into Its shown to 9n Fatae Balessre art 0, 'Mid m1a s MOWN d
.' Us Uft do ftsm-400
shy foe T ats bab...' it to" is h do IwIOw+ Bsirrtrtsa aitimuts peppwnt
isnrrbtDh w did net rot blog the ngvlrs
llopno, mby dw dro?a B"
ltv"* day rlerco is Moor urf 1 ?dh Is, W, plat' 'Imo tog tsl
Vol, evwt it a dr
o easdklnbwsw rter tw eve pd ON
ar A la v estb,dnd an V"&A join swbw aosl p»t YWr
b9n tYtI& Bova on C yew arm* & N yata ,
toed tfs ``bled
ere reads an tad
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SHERIFF'S RETURN - REGULAR
CASE NO: 2008-01784 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CHASE BANK USA NA
VS
SHORT THOMAS J AKA THOMAS JR
GERALD WORTHINGTON , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
SHORT THOMAS J AKA THOMAS J SHORT JR the
DEFENDANT , at 2005:00 HOURS, on the 3rd day of April 2008
at 2397 LAMBS GAP ROAD
ENOLA, PA 17025
THOMAS J SHORT II
by handing to
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 18.00
Service 11.00
Affidavit .00
Surcharge 10.00
I
bit 00
39.00
Sworn and Subscibed to
before me this day
So Answers:
R. Thomas Kline
04/04/2008
WELTMAN WEINBERG REIS
By:
Deputy S iff
of A. D.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE BANK USA, N.A.
Plaintiff
vs.
THOMAS J SHORT
AKA THOMAS J SHORT II
Defendant
No. 08-1784
PRAECIPE FOR DEFAULT JUDGMENT
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Moiczan, 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#06524644
Judgment Amount 11219.33
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
CHASE BANK USA, N.A.
Plaintiff
vs.
THOMAS J SHORT
AKA THOMAS J SHORT 11
Defendant
TO THE PROTHONOTARY:
Civil Action No. 08-1784
PRAECIPE FOR DEFAULT JUDGMENT
COUNTI
Kindly enter Judgment against the Defendant, THOMAS J SHORT, above named, in the default
of an Answer, in the amount of $7977.57 computed as follows:
Amount claimed in Complaint $7739.78
Interest from March 7, 2008 to May 15, 2008 $87.79
at the legal interest rate of 6% per annum
Attorney's fees $150.00
TOTAL $7977.57
COUNT 11
Kindly enter Judgment against the Defendant, THOMAS J SHORT, above named, in the default
of an Answer, in the amount of $3241.76 computed as follows:
Amount claimed in Complaint $3057.09
Interest from March 7, 2008 to May 15, 2008 $34.67
at the legal interest rate of 6% per annum
Attorney's fees $150.00
TOTAL $3241.76
TOTAL COUNT I & COUNT 11 $11219.33
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:
William T. Molc n, Esquire
PA. I. D.#4743
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#06524644
Plaintiff's 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: 59 WALNUT ST, BEAVER,PA 15009
IN THE, COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE BANK USA, N.A.
Plaintiff
THOMAS J SHORT
Defendant(s)
IMPORTANT NOTICE
TO: THOMAS J SHORT
2397 LAMBS GAP RD
ENOLA,PA 17025
Date of Notice: 0LII30IOP
WWR#: 06524644
Case # (3(j - 1-V 8q
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
BY :-T 9. - 1}c CtA LbC)o ryvw `--
PATRICK THOMAS WOODMAN
PA I.D. #34507
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 KOPPERS BLDG, 436 7TH AVE.
PITTSBURGH, PA 15219
IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE BANK USA, N.A
Plaintiff
vs.
THOMAS J SHORT
AKA THOMAS J SHORT 11
Defendant
Case no: 08-1784
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,
THOMAS J SHORT
AKA THOMAS J SHORT II 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, THOMAS J SHORT
AKA THOMAS J SHORT II, is not in the military service.
Further Affiant sayeth naught.
AFFIANT.
4
SW N TO AND SUBSCRIBE11D m y presence this ? day
of =? ?-4J
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
RY PUBLIC JenniterM.Borowski, Notary Public
City of Pittsburgh, Allegheny County
Commission Expires Feb. 22, 2012
Member, Pennsylvania Association of 140tailles
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
MAY-21-2008 11:53:32
'< Last Name First/Middle Begin Date Active Duty Status Service/Agency
SHORT thomas j 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 . A(?N_
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: ft://www.defenselink.mil/faq/pis/PC09SLDR.htrnl
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 5/21/2008
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IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE BANK USA, N.A.
Plaintiff
vs. Civil Action No. 08-1784
THOMAS J SHORT
AKA THOMAS J SHORT 11
Defendant
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the following
Order or Jud m nt was entered against
you on 09
(xx) Assumpsit Judgment in the amount
of $7977.57 plus costs as to Count I.
(xx) Assumpsit Judgment in the amount
of $3241.76 plus costs as to Count II.
( ) 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
THOMAS J SHORT
2397 LAMBS GAP RD
ENOLAPA 17025 By:
9A * I V_
PR ONOTAR PUTY)
Plaintiff's address is:
c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219
1-888-434-0085
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE BANK USA, N.A.
Plaintiff
vs.
THOMAS J SHORT
Defendant
SOVEREIGN BANK,
Garnishee,
No. 08-1784
PRAECIPE FOR WRIT OF EXECUTION
(BAND ATTACAIIENT ONLY and LEVY)
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 Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR No. 06524644
a- • . .
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE BANK USA, N.A.
Plaintiff
vs. Civil Action No. 08-1784
THOMAS J SHORT
Defendant
SOVEREIGN BANK,
Garnishee
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Kindly issue a Writ of Execution in the above matter... p?
1. directed to the Sheriff of CUMBERLAND County:
2. against THOMAS J SHORT, Defendant, &sql Lambs 'Gap Pj , Fnolm PA Iz09.6
3. against SOVEREIGN BANK, Garnishee,&to% N. Enolo. AA, En AL. PA 170aS
4. Judgment Amount $ 11219.33
Less payments of $ 183.46
Interest $ 330.11
Costs $
SUBTOTAL: $ 11365.98
Costs (to be added by Prothonotary): $
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
William T Mo an Esquire
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#06524644
WWR No. 06524644
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE BANK USA, N.A.
Plaintiff
vs. Civil Action No. 08-1784
THOMAS J SHORT, d3q I LO^n A (6P RD(
Enola. PA 170SS
Defendant
SOVEREIGN BANK, µ01 N. £r?o(a 6W ,Enola. PA scar
Garnishee
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Kindly issue a Writ of Execution in the above matter...
1. directed to the Sheriff of CUMBERLAND County:
2. against THOMAS J SHORT, Defendant *"+OtA proPv1-kjoPc6?}
3. against SOVEREIGN BANK, Garnishee
4. Judgment Amount $ 11219.33
Less payments of $ 183.46
Interest $ 330.11
Costs
$ 192.50 j
SUBTOTAL: $ 11365.98
Costs (to be added by Prothonotary): $
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
William T Molczan quire
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#06524644
WWR No. 06524644
a?4
Q
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00
a?
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-1784 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CHASE BANK USA, N.A., Plaintiff (s)
From THOMAS J. SHORT, 2397 Lambs Gap Road, Enola, PA 17025
(1) You are directed to levy upon the property of the defendant (s)and to sell any and all property .
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
SOVEREIGN BANK, 401 N. Enola Road, Enola, PA 17025
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 $11,035.87
Interest -- $330.11
Atty's Comm %
Atty Paid $158.50
Plaintiff Paid
Date: 8/12/08
(Seal)
L.L. $.50
Due Prothy $2.00
Other Costs
A4?-'-WIL
s R. L o o tary
By:
Deputy
REQUESTING PARTY:
Name WILLIAM T. MOLCZAN, ESQUIRE
Address: WELTMAN, WEINBERG & REIS CO., LPA
1400 KOPPERS BUILDING
436 SEVENTH AVENUE
PITTSBURGH, PA 15219
Attorney for: PLAINTIFF
Telephone: 412434-7955
Supreme Court ID No. 47437
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE BANK USA, N.A.
Plaintiff
VS.
THOMAS J SHORT
Defendant
and
SOVEREIGN BANK
Garnishee
Civil Action No.: 08-1784
TO: SOVEREIGN BANK Suggested Reference No.: XXX-XX-3769
401 N Enola Rd
Enola, PA 17025
RE: THOMAS J SHORT
2397 LAMBS GAP ROAD
ENOLA, PA 17025
IWORTANT 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.
WWR No. 06524644
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?
No
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 that you owe or owed to him; and the nature and amount of each of such liabilities.
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.
Yes-See Attached
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?
No
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?
No
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?
No
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?
No
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 entity electronically depositing those funds on a recurring
basis.
No W WR No. 06524644
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.
No-See Attached
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
William T Molczan Es re
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#06524644
W WR No. 06524644
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 Timothy J. Cooney
(Name)
C.O.P. Team Leader of Sovereign Bank , 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.
(SI ATURE)
wWR No. 06524644
ANSWERS TO INTERROGATORIES
Account # 0571200087 Balance: $1,378.40
After allowing for the $300.00 exemption under 42 Pa.C.S. 8123 the balance in this
account is $1,078.40
Account Holder: Thomas J Short
Georgia G Short
2397 Lambs Gap Rd
Enola, PA 17025-1161
VERIFICATION
I, Timothy J. Cooney, C.O.P. Team Leader of Sovereign Bank, hereby verify that the
information contained in the foregoing Answers to Interrogatories in Attachment are true
and correct to the best of my knowledge, information and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. Section 4094,
relating to unsworn falsification to authorities.
Sovereign Bank
By: 14.YW
Timothy J. Cooney
C.O.P. Team Leader
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
IN RE:
Chase Bank USA, N.A.
VS.
Thomas J Short
CERTIFICATE OF SERVICE
I hereby certify that on or before the date of filing the following documents(s):
Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of
Execution, Claim for Exemption Order and Claim for Exemption
I have served a copy thereof on each of the following persons in the manner
indicated below:
Service by first class mail addressed as follows:
William T. Molczan, Esquire
Weltman, Weinberg & Reis Co., L.P.A.
1400 Koppers Building 436 Seventh Avenue
Pittsburgh, PA 15219
Service by certified mail addressed as follows:
Thomas J Short
2397 Lambs Gap Rd
Enola, PA 17025-1161
Timothy J. Cooney
C.O.P. Team Leader
Sovereign Bank
MA1 M133-02-10
2 Morrisey Boulevard
Boston, MA 02125
September 5, 2008
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE BANK USA, N.A.
Plaintiff
VS.
THOMAS J SHORT
Defendant
SOVEREIGN BANK
Garnishee
No. 08-1784
PRAECIPE FOR JUDGMENT AGAINST
GARNISHEE
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#06524644
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE BANK USA, N.A.
Plaintiff
vs. Civil Action No. 08-1784
THOMAS J SHORT
Defendant
SOVEREIGN BANK
Garnishee
PRAECIPE FOR JUDGMENT AGAINST GARNISHEE
TO THE PROTHONOTARY:
Kindly enter Judgment against the Garnishee, SOVEREIGN BANK, in the amount of $1078.40, which is
less than Defendant owes to Plaintiff and which amount Garnishee has admitted owing to the Defendant, in answers
to Interrogatories.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
WILLIAM T. LCZAN, ESQUIRE
PA I.D.#4743
Weltman, Weinberg & Reis Co., L.P.A.
1400 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#06524644
I hereby certify that the address of the Plaintiff is:
c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7h Avenue, Pittsburgh, PA 15219
And that the last known address of the Garnishee is: 401 N ENOLA ROAD, ENOLA, PA 17025
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE BANK USA, N.A.
Plaintiff
VS.
THOMAS J SHORT
Defendant
and
SOVEREIGN BANK
Garnishee
Civil Action No.: 08-1784
TO: SOVEREIGN BANK Suggested Reference No.: XXX-XX-3769
401 N Enola Rd
Enola, PA 17025
RE: THOMAS J SHORT
2397 LAMBS GAP ROAD
ENOLA, PA 17025
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.
W WR No. 06524644
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? is
No
Ia. 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 that you owe or owed to him; and the nature and amount of each of such liabilities.
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.
Yes-See Attached
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?
No
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?
No
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?
No
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?
No
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 entity electronically depositing those funds on a recurring
basis.
No WWR No. 06524644
8. If you are a bank or other financial institution, at the time you were served or at any subsequent
time did defendant have funds on deposit in an account in which the funds on deposit, oot 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.
No--See Attached
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
William T Molczan Es re
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#06524644
WWR No. 06524644
VERIFICATION
O
The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating
to unworn falsifications to authorities, that he/she is Timothy J. Cooney
(Name)
C.A.P. Team Leader
(Title)
of Sovereign Bank , garnishee herein,
(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.
(SI ATURE)
WWR No. 06524644
ANSWERS TO INTERROGATORIES
Account # 0571200087 Balance: $1,378.40
After allowing for the $300.00 exemption under 42 Pa.C.S. 8121Ahe balance in this
account is $1,078.40
Account Holder: Thomas J Short
Georgia G Short
2397 Lambs Gap Rd
Enoia, PA 17025-1161
VERIFICATION
I, Timothy J. Cooney, C.O.P. Team Leader of Sovereign Bank, hereby verify that the
information contained in the foregoing Answers to Interrogatories in Attachment are true
and correct to the best of my knowledge, information and belief. I understand that false
statements herein are made subject to the penalties of 18 Pa. C.S. Section 4094,
relating to unsworn falsification to authorities.
Sovereign Bank
By: 99z/
Timothy J. Cooney
C.O.P. Team Leader
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
IN RE:
Chase Bank USA, N.A.
VS.
Thomas J Short
CERTIFICATE OF SERVICE
I hereby certify that on or before the date of filing the following documents(s):
Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of
Execution, Claim for Exemption Order and Claim for Exemption
I have served a copy thereof on each of the following persons in the manner
indicated below:
Service by first class mail addressed as follows:
William T. Molczan, Esquire
Weltman, Weinberg & Reis Co., L.P.A.
1400 Koppers Building 436 Seventh Avenue
Pittsburgh, PA 15219
Service by certified mail addressed as follows:
Thomas J Short
2397 Lambs Gap Rd
Enola, PA 17025-1161
I'll
Timothy J. Cooney
C.O.P. Team Leader
Sovereign Bank
MA1 M133-02-10
2 Morrisey Boulevard
Boston, MA 02125
September 5, 2008
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IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE BANK USA, N.A.
Plaintiff
VS. Civil Action No. 08-1784
THOMAS J SHORT
Defendant
SOVEREIGN BANK
Garnishee
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
( ) Defendant
(xx) Garnishee
You are hereby notified that the
following Order or Judgment was
entered against you on Ieg
(xx) Assumpsit Judgment in the amount
of $1078.40 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
( ) Default
( ) Verdict
( ) Arbitration
Award
Prothonotary
A, t?_
By:
P HONO EPUTY)
_T_A?
Sovereign Bank
401 N Enola Road
Enola, Pa 17025
SHERIFF'S RETURN - GARNISHEE
CASE NO: 2008-01784 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY OF CUMBERLAND
CHASE BANK USA NA
VS
SHORT THOMAS J AKA THOMAS JR
And now WILLIAM CLINE
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0008:55 Hours, on the 26th day of August , 2008, attached
as herein commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
SHORT THOMAS J
in the
hands, possession, or control of the within named Garnishee
SOVEREIGN BANK 17 W HIGH ST
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
DEINISE BEECHER (TELLER) ,
personally three copies of interogatories together with 3 true
and attested copies of the within WRIT OF EXECUTION and made
the contents there of known to Her .
Sheriff's Costs: S
Y
Docketing .00
Service .00 '
Affidavit .00 R. Thomas Kline
Surcharge .00 Sheriff of Cumberland County
.0000 ?G/a,L?c?
09/23/2008
Sworn and Subscribed to
before me this day of By
Depu y Sheriff
A.D
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE BANK USA, N.A.
Plaintiff
VS.
THOMAS J SHORT
Defendant
SOVEREIGN BANK
Garnishees
No. 08-1784
PRAECIPE TO SETTLE, DISCONTINUE
& END AS TO THE GARNISHEES
SOVEREIGN BANK ONLY
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.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#06524644
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE BANK USA, N.A.
Plaintiff
vs.
THOMAS J SHORT
Defendant
SOVEREIGN BANK
Garnishees
Civil Action No. 08-1784
PRAECIPE TO SETTLE DISCONTINUE AND END
AS TO THE GARNISHEE. SOVEREIGN BANK, ONLY
TO THE PROTHONOTARY OF COUNTY:
Please kindly Settle Discontinue -and End the above captioned matter as to Garnishee, SOVEREIGN BANK,
only, upon the records of the Court and mark the cost paid.
WELTMAN, WEINBERG & REIS CO., L.P.A.
Sworn to and subscribed
Before me the /0
By:
James D C. W rodt
PA I. #425N
WEL INBERG & REIS CO., L.P.A.
1400 Ko ers ilding
436 Sev nth enue
(412
'A 15219
WWR#06524644
Day,, October, 08
COMMONWEALTH OF PENNSYLVANIA
UBLIC Notarial Seal
Jennifer M. Borowski, Notary Public
City of Pittsburgh, Agegheny County
My Commission rss Feb. 22, 2012
Member. Pennsylvania Association of Notaries
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE BANK USA NA
Plaintiff No. 08-1784
vs. PRAECIPE TO VACATE JUDGMENT AS TO
THE GARNISHEE, SOVEREIGN BANK ONLY
THOMAS J SHORT
Defendants FILED ON BEHALF OF
SOVEREIGN BANK Plaintiff
Garnishee
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan, Esquire
PA I. D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#6524638
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CHASE BANK USA NA
Plaintiff
vs.
THOMAS J SHORT
Civil Action No. 08-1784
Defendants
PRAECIPE TO VACATE JUDGMENTAS TO THE GARNISHEE SOVEREIGN BANK ONLY
TO THE PROTHONOTARY OF CUMBERLAND COUNTY:
SIR:
Kindly vacate the judgment entered in the above case on 1011108, as to the Garnishee, Sovereign
Bank only, as the Defendant Thomas J Short has filed Bankruptcy.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By: lam" 1
Attorney for intiff
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#6524638
r
PI
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 18.00
Poundage 2.59
Law Library .50
Prothonotary 2.00
Mileage 19.00
Surcharge 40.00
Levy 40.00
Postage .88
Garnishee 9.00
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.
131.97 ? 4
Advance Costs: 300.00
Sheriff's Costs: 131.97
168.03
Refunded on 05/29/09
So Answers,
By
R. Lantz
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-1784 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CHASE BANK USA, N.A., Plaintiff (s)
From THOMAS J. SHORT, 2397 Lambs Gap Road, Enola, PA 17025
(1) You are directed to levy upon the property of the defendant (s)and to sell any and all property .
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
SOVEREIGN BANK, 401 N. Enola Road, Enola, PA 17025
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 defendas) 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 $11,035.87
Interest - $330.11
Atty's Comm %
Atty Paid $158.50
Plaintiff Paid
L.L. $.50
Due Prothy $2.00
Other Costs
Date: 8/12/08
(Seal)
REQUESTING PARTY:
Name WILLIAM T. MOLCZAN, ESQUIRE
Address: WELTMAN, WEINBERG & REIS CO., LPA
1400 KOPPERS BUILDING
436 SEVENTH AVENUE
PITTSBURGH, PA 15219
Attorney for: PLAINTIFF
Telephone: 412434-7955
s R. Lon a o
By:
Deputy
Supreme Court ID No. 47437