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HomeMy WebLinkAbout08-2266H Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. TIMOTHY G LUMSDEN Defendant No : D8 - aka to(o Ierk 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 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 06558347 C A Pit SXA in Tssommy W andtM90 Of REGORE) 9 unto sot my hart &t Carlisle, Pa. ?n1 otp!b I I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No TIMOTHY G LUMSDEN 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 It 1 r COMPLAINT 1. Plaintiff, is a corporation with offices at 6500 New Albany Rd, New Albany, OH 43054. 2. Defendant is adult individual(s) residing at the address listed below: TIMOTHY G LUMSDEN 12 S. FILBERT ST C8 MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXXXXXX9015 . A copy of Plaintiff's Statement of Account s attached hereto, marked as Exhibit "A" and made a part hereof. 4. Defendant made use of said credit card and currently has a balance due and owing to Plaintiff, as of March 26, 2008 , in the amount of $12290.11 . 5. Defendant is in default by failing to make payments when due. 6. Plaintiff avers that the Agreement between the parties provides that Defendant will pay Plaintiff's attorneys! fees. 7. Plaintiff avers that such attorneys' fees will amount to $1500.00 1 8. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for Judgment in its favor and against Defendant , TIMOTHY G LUMSDEN INDIVIDUALLY , in the amount of $12290.11 with interest at the legal rate of 6.000. per annum from date of judgment plus attorneys' fees of $1500.00 , and costs. James "Warmbrodt,42524 WELTM , WEINBERG & REIS CO., L.P.A. 436 S ve th Avenue, Suite 1400 Pitt ur h, PA 15219 (412 4 4-7955 FAX. 4 -338-7130 06 58 47 C A Pit SXA This law firm is a debt collector att ting to collect this debt for our client and any information obtain will be used for that purpose. New botance ! Minimum rayment uue I Account Number ending to YV I a DISC VER $0.00 $2,427.00 Enter Amount Enclosed Below ,:ate - C, R', ?? +1 Payment Due Date $ I January 30, 2008 31 SDSN6A01 0007464 TIMOTHY LUMSDEN PO BOX 91 MECHANICSBURG PA 17055-0091 Address, e-mail or telephone change? Print change in space above, or go to Discovercard.com. Print your e-mail address to receive important Account information and special offers. Know what's on your statement-before you even get it. Keep track online with daily updates and up to 12 months of history. Visit Di3covercard.com/register PO BOX 15251 "' WILMINGTON DE 19886-5251 11111111 if III IIrIt,Ir,111111111111111lr111n111111rirt11111111 000006011002830679015000000000000000242700 Discover More Card Account Summary Closing Date: December 31, 2007 page 1 of 1 Account number ending in 9015 Previous Balance $12,290.11 Payment Due Date January 30, 2008 Payments And Credits - 12,290.11 Minimum Payment Due $2,427.00 Purchases + 0.00 Credit Limit $9,900.00 Cash Advances + 0.00 Credit Available $0.00 Balance Transfers + 0.00 Cash Credit Limit $5,000.00 Finance Charges + 0.00 Cash Credit Available $0.00 New Balance - $0.00 Cashback Boma' Opening Cashback Bonus Balance $ 0.00 New Cashback Bonus Earned + 0.00 Cashback Bonus Balance $ 0.00 Cashback BonusS Anniversary _ _ _ _ _ Available to Redeem $ 0.00 Date: October 5 How Can We Help You? For Account Inquiries, write to us at- Discover More Card, PO Box 30943 Please have your Discover Card available. Salt Lake City, UT 84130 Manage your account online at Discovercard.com TDD (Telecommunications Device for the Deaf): Customer Service: 1-800-DISCOVER (1-800-347-2683) For assistance, see reverse side. Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence. Trans. Post Date Date Payments and Credits Dec 31 Dec 31 INTERNAL CHARGE-OFF $ -12,290.11 EXH,?BIT ?I Finance Charge Summary Nominal Transaction Average Daily ANNUAL ANNUAL Periodic Fee Daily Periodic PERCENTAGE PERCENTAGE FINANCE FINANCE Balances Rates RATES RATES CHARGES CHARGES current billing period: 26 days Purchases $0 0.07942 0 28.99% F 9R 9901_ cn ???- 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 Robert Adkins (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. _Signa ,., cc) WWR # 6558347 TIMOTHY G LUMSDEN 6011002830679015 K" r d1 w ; T' D IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. TIMOTHY G LUMSDEN Defendant No. 08-2266-CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire PA I.D. #42524 WELTMAN, WEINBERG & REIS, CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6558347 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 08-2266-CIVIL TERM TIMOTHY G LUMSDEN Defendant PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By. brodt, Esquire TamP#2 PA WEEINBERG & REIS CO., I,.P.A. 140ui lding 436 enue Pitts 5219 (412 WWR #6558347 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. TIMOTHY G LUMSDEN Defendant No. 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 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 06558347 C A Pit SXA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No TIMOTHY G LUMSDEN Defendant COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff, is a corporation with offices at 6500 New Albany Rd, New Albany, OH 43054. 2. Defendant is adult individual(s) residing at the address listed below: TIMOTHY G LUMSDEN 12 S. FILBERT ST C8 MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXXXXXX9015 . A ropy of Plaintiff's Statement of Account s attached hereto, marked as Exhibit "A" and made a part hereof. 4. Defendant made use of said credit card and currently has a balance due and owing to Plaintiff, as of March 26, 2008 , in the amount of $12290.11 . 5. Defendant is in default by failing to make payments when due. 6. Plaintiff avers that the Agreement between the parties provides that Defendant will pay Plaintiff's attorneys! fees. 7. Plaintiff avers that such attorneys' fees will amount to $1500.00 8. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for Judgment in its favor and against Defendant , TIMOTHY G LUMSDEN INDIVIDUALLY , in the amount of $12290.11 with interest at the legal rate of 6.000 per annum from date of judgment plus attorneys' fees of $1500.00 , and costs. James, Warmbrodt,42524 WELT , WEINBERG & REIS CO., L.P.A. 436 S ve th Avenue, Suite 1400 Pitt ur h, PA 15219 (41 4 4-7955 FAX 4 -338-7130 06 58 7 C A Pit SXA This law firm is a debt collector attting to collect this debt for our client and any information obtainLwd will be used for that purpose. IVew Balance I Minimum Yoyment Uue I Account NUM!aer ending in YV 10 DISCOVER $0.00 I $2,427.00 J Enter Amount Enclosed Below d r CARD . -.4111 Payment Due Date U I January 30, 2008 31 SDSN6A01 0007464 TIMOTHY LUMSDEN Know what's on your statement-before you PO BOX 91 even get it. Keep track online with daily updates and up to 12 months of history. Visit MECHANICSBURG PA 17055-0091 Discovercard.com/register PO BOX 15251 space WILMINGTON DE 19886-5251 Address, e-mail or telephone above, or go to Discovca d. om Print your e-mailnaddress to receive important Account information and special offers. 000006011002830679015000000000000000242700 Discover More Card Account Summary Closing Date: December 31, 2007 page 1 of 1 Account number ending in 9015 Previous Balance $12,290.11 Payment Due Date January 30, 2008 Payments And Credits - 12,290.11 Minimum Payment Due $2,427.00 Purchases + 0.00 Credit Limit $9,900.00 Cash Advances + 0.00 Credit Available $0.00 Balance Transfers + 0.00 Cash Credit limit $5,000.00 Finance Charges + 0.00 Cash Credit Available $0.00 New Balance = $0.00 Cashback Bonus® Opening Cashback Bonus Balance $ 0.00 New Cashback Bonus Earned + 0.00 Cashback Bonus Balance $ 0.00 Cashback Bnnu3O Anniversary-y - - - - - - - - - - - - - - - -. - - - - - - .Available to Redeem $ 0.00 Date: October 5 .How Can We Help You? For Account Inquiries, write to us at Please have your Discover Card avaiabb. Discover More Card, PO Box 30943 Salt Lake City, UT 84130 Manage your account online at Diseovemard.com TDD (Telecommunications Device for the Deal): Customer Service: 1-800-DISCOVER (1-800-347-2683) For assistance, see reverse side. Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence. Trans. Post Date Date Payments and Credits Dec 31 Dec 31 INTERNAL CHARGE-OFF $ -12,290.11 XH BIT Finance Charge Summary Nominal Transaction Average Daily ANNUAL ANNUAL Periodic Fee Daily Periodic PERCENTAGE PERCENTAGE FINANCE FINANCE Balance s Rates RATES RATES CHARGES CHARGES current billing period: 26 days Purchases $0 0.07942% 28.99% F 28.99% $0 none VERIFICATION 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 Robert Adkins (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. Signature) WWR # 6558347 TIMOTHY G LUMSDEN 6011002830679015 96 04 _? t i "* SHERIFF'S RETURN - REGULAR CASE NO: 2008-02266 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS LUMSDEN TIMOTHY G KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon T TT%ff0TInTT R+TArtnrPTJV r_ the DEFENDANT , at 1601:00 HOURS, on the 17th day of October , 2008 at 18 W KELLER STREET MECHANICSBURG, PA 17055 PENNY LUMSDEN, WIFE by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge /V20.- `- So Answers: 18.00 11.00 .00 ' 10.00 R. Thomas Kline .00 39.00 10/20/2008 WELTMAN Sworn and Subscibed to before me this of By: day A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. TIMOTHY G LUMSDEN Defendant No. 08-2266-CIVIL TERM PRAECIPE 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#6558347 Judgment Amount $ 13,790.11 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. e4. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 08-2266-CIVIL TERM TIMOTHY G LUMSDEN Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, TIMOTHY G LUMSDEN above named, in the default of an Answer, in the amount of $13,790.11 computed as follows: Amount claimed in Complaint $12,290.11 Interest from date of judgment at the legal interest rate of 6.00% per annum Attorney's fees $1,500.00 TOTAL $13,790.11 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. MolczanXsquire PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6558347 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A.,1400 Koppers Building, 436 7d Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 18 W KELLER ST, MECHANICSBURG,PA 17055 y IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff Case # 1e%r 0-1 TIMOTHY G LUMSDEN Defendant(s) IMPORTANT NOTICE TO: TIMOTHY G LUMSDEN 18 W KELLER ST MECHANICSBURG+, P)A 1?7055 Date of Notice: t D a /J01 WWR#: 06178425 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 : ?au,C . Wbl9 PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 (412) 434-7955 11 t' IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. TIMOTHY G LUMSDEN Defendant Case no: 08-2266-CIVIL TERM 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, TIMOTHY G LUMSDEN 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, TIMOTHY G LUMSDEN is not in the military service. Further Affiant sayeth naught. / / W AFFIANT SW ?n?-?TO AND SUBSCRIBED in my presence this day of !)C'r-e-rv? NOT CC.''i.;IONWEALTH OF PENNSYLVA,` Notarial Seal Wordy L. Gault, Notary Public y Cly Of Pittsburgh, Allegheny County My Cnmml.,sion Expires July 15, 2010 Member, peronsylvania Association of Notaries This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. Request for Military Status ,Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page DEC-08-2008 09:18:50 Last Name First/Middle Begin Date Active Duty Status Service/Agency LUMSDEN TIMOTHY 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. IA. ojfot y6t pt 414, 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/faq/pis/PC09SLDR.htmi WARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: BXWVRJAMGBG https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 12/8/2008 N R. :F' 00 tin °) v 01 v 'C, c'Tm C? C 3 fTl ? :_ c l ?..?' ' C ) _ ....r - .. Y c5f'ti G. ? 4- ' N IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 08-2266-CIVIL TERM TIMOTHY G LUMSDEN Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judgment was entered against you on (xx) Assumpsit Judgment in the amount of $13,790.11 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: PRO'f HONG OR D UTY) TIMOTHY G LUMSDEN 18 W KELLER ST MECHANICSBURG, PA 17055 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7'h Avenue, Pittsburgh, PA 15219 1-888-434-0085 WELTMAN,WEINBERG&REIS CO.,L.P.A. BY: William T Molczan,Esquire Attorney for Plaintiff(s) I.D.No.47437 c_ 436 Seventh Avenue, Suite 1400 a Pittsburgh,PA 15219 MC Phone: 412.434.7955 rn � Fax: 412.434.7959 f— N a2 File#6558347 -< ..4a Z"p -- DISCOVER BANK 5a 77 Cumberland County Court of Common Pleas co vs. TIMOTHY G LUMSDEN NO. 08-2266-CIVIL TERM and PNC BANK Garnishee(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter discontinued and ended as to Garnishee(s),PNC BANK, only. WELTMAN,WEINBERG&REIS CO.,L.P.A. By William T Molczan,Esquir Attorney for Plaintiff �q.50 PA KT1'', e* /I ooq(013 0-.188aa8 SHERIFF'S OFFICE-OF CUMBERLAND COUNTY Ronny R Anderson :tr � ,o Sheriff �11 Z`a°�n-t 'n "r- teti%jp 4 Glr�rri 7x 3 i H f�RO ! HON W�A,ti'a Jody S Smith ° Chief Deputy 7013 SEP 19 API ft. � Richard W Stewart Solicitor OUICEOF THE SRERIF- CUMBERLAti-D CC)Upffy PEN?4SYLVAMA Discover Bank Case Number vs. Timothy G Lumsden 2008-2266 SHERIFF'S RETURN OF SERVICE 02/15/2013 10:13 AM-William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, PNC Bank, 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Susan Casale, Customer Service Rep., personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on February 20, 2013 to Timothy G. Lumsden, 18 W Keller Street, Mechanicsburg, PA 17055. 09/18/2013 Ronny R.Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $87.93 SO ANSWERS, September 18, 2013 RbNW R ANDERSON, SHERIFF �'3 (c)Cou:^:tySWte Shenft,Teleosoft,Inc.