HomeMy WebLinkAbout08-2687
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK '.
Plaintiff No: ??' o?w0 7 Cam'
VS.
COMPLAINT IN CIVIL ACTION
MARY P FULTON
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
06413764 C A Pit SXA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No
MARY P FULTON
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:
MARY P FULTON
6354 MERCURY DR
MECHANICSBURG, PA 17050
3. Defendant applied for and received a credit card issued by
Plaintiff bearing the account number XXXXXXXXXXXXXXXX6619 . 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 April 09, 2008 , in the amount of
$9581.56 .
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 , MARY P FULTON INDIVIDUALLY , in the amount of
$9581.56 with interest at the legal rate of 6.000% per annum from date
of judgment plus attorneys' fees of $1500.00 , and costs.
James %armbrodt,42524
WELT WEINBERG & REIS CO., L.P.A.
436 S ve th Avenue, Suite 1400
Pitts ur h, PA 15219
(412 43 -7955
FAX: 41 -338-7130
064 376 C A Pit SXA
This law firm is a debt collector atteopt/ng to collect this debt for
our client and any information obtaineF,dill be used for that purpose.
DISC.UVEK $10,085.56 I $10,085.56 Enter Amount Enclosed Llow
CARD
Payment Due Date $ ?-
DUE IMMEDIATELY
08 SDSN6A010006717
MARY FULTON
6354 MERCURY DR
MECHANICSBURG PA
17050-5268
Address, e-mail or telephone change? Print change ins ace
above, or go to Discovercard.com. Print your e-mail address to
receive important Account information and special offers.
00000601100243950661910085561
Make payments on your schedule, in
advance or on the same day as your due
date. Visit Disooveroard.oomlpayments
to make an online payment today.
PO BOX 15251
WILMINGTON DE 19886-5251
10000001008556; ;;.
i'Jf
Discover Open Road Card Account Summary
Closing Date: November 8, 2007 page 1 of 1
Account number ending in 6619
Payment Due Date December 7, 2007
Minimum Payment Due $10,085.56
Credit Limit $7,750.00
Credit Available $0.00
Cash Credit Limit $0.00
Cash Credit Available $0.00
Previous Balance $10,085.56
Payments And Credits 0.00
Purchases + 0.00
Cash Advances + 0.00
Balance Transfers + 0.00
Finance Charges + 0.00
New Balance = $10,085.56
Cashback Bonus-
Gas & Auto
Cashback Banus® Anniversary - - -
Date: February 8
Opening Cashback Bonus Balance $ 0.00
New Cashback Bonus Earned + 0.00
Cashback Bonus Balance $ 0.00
_.__ ______Available_taltedeettm__ _- _. $ _ __.__0..00_ _.
How Can We Help You? For Account Inquiries, write to us at
Please have your Discover Cord available. Discover More Card, PO Box 30943
Salt Lake City, UT 84130
Manage your account online at Discovercard.com TOO (Telecommunications Device for the Doo:
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.
Information For You
While we are permitted under the Cardmember Agreement to increase the APRs on your Account because your payment
was late, we have chosen not to do so at this time. However, we reserve the right to increase the APRs on your Account if
you fail to pay the minimum payment due by the payment due date. See the Default Rate Plan section of the Cardmember
Agreement for details.
tWBIT
A-
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: 31 days
Purchases $0 0.07942`Yo 28.99% F 28.99% $0 none
Cash Advances $0 0.07942% 28.99% F 28.99% $0 $0
previous billing period: 8 days
Purchases $0 0.07942% 28.99% F 28.99% $0 none
The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above.
ImpataK kdwmatbn. If there is more than one page to this billing statement see the back of each page for additional important information.
See your Cadraahrber Agreement. Your Cardmember Agreement contains all the terms of your Account
Lost or stalan cards. Report immediately! Call 1400447-2683.
Rrts "me In Case of Errors or Questions About Your Bill: 9 you think your bill is wrong or if you need more information about a
00 %t
Ua n oih on your bH write us on a separate sheet of paper at Discover Open Roadsu ; P.O. Box 15112; WGnnnplon DE 19850-5192, 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
ti , but doing so will not preserve your rights In your leter, give us the folowing information:
Your name and Account number.
*The dollar amount of the suspected error.
*Describe the error and 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 invesigate your question, we cannot report you as delinquent or take any action to collect the amount you question.
Spedal Rule for Craw Card Praclraes: If u have a problem with the quality of goods or services that you purchased with a credit card, and
you .have Died in goad faith to correct the problem with the merchant you ma not have to pay Ne remaining amount due on the goods or
services You have Nis protection only when the purchase price was. more than S50 and the purc ase was man in your home state or within 100
miles of your makng address (If we own or date Ne merchant or d we mailed you Ne advertisement for the goods or services, all purchases are
covered regardless o< the airrount or location of purchase.)
Payrnarts. Send only your payment and. the top portion of this statement in the envelope provided. Do not send cash. By sending your check as
described above, you auNor2e us t o use information on your check to make an electronic fund transfer from your atxarrnt at the financial insitution
indicated on your check or to process the payment as a. chack transaction. If payment is processed as an electronic fund transfer, the transfer will
be for the amount of the check. When we use information from your check to make an electronic fund transfer funds may be withdrawn from your
account as soon as Ne same day we receive yyour payment and you will not receve your check back from your jinamedal institution.
The processing of your payment may be data if you send cash, correspondence or other gerrhs with your payment if you send the payment to
any other address or d you use an envelope other than the one-provided, Payments received on or after-1 FM Monday through Friday a on a
weekend or bank holitlaY will be posted to ur Account as of the next business day. K you have misplaced your envelope, send your payment to
Discover Bank, PO Box 15251 W)Imi n, DE 19886-5251. Please allow 7.10 days for delivery. If your payment is returned unpaid, we reserve the
right to resubmit it as an elec(ronic de it
You can pay your minimum payment or a greater amount over the telephone. Call us at 1-800.347-2683. You will need this statement and your
bank account information. You must ensure that sufficient funds are available in your bank account, an all transactions must comply with U.S. law.
You will be asked to provide the first 5 digits of your account statement zip code. By entering those numbers as your electronic signature, you will be
agreeing to this authorization to allow us and your bank to deduct each payment you authorize. in the amount requested by u, from your bank
account In order to cancel a payment we must receive notice at least three days in advance of the scheduled payment Yo may notify us by
phone at 1-800-347-2683 or by marl at address listed in the previous paragraph.
Craft Raper". We may report information about your account to credit bureaus. Late yments, missed payments, or other defaults on your
account may be reflected in your credit. report. We normally report the status and payment Acr of Wt Account to credit reporting aMcies each
plete, month. If you believe that our report is inaccurate or incom ease write us at the t p address: Discover Open Road" Card, PO Box
15316, Wilmington DE 19850-5316. Please include your name, address, home telephone number and Account number.
PERIODIC FINANCE CHARGES. Periodic Finance Charges are imposed on all transactions from the date the transaction is posted to your Account
until the date you pay your entire New Balan Dice, by making payments or receiving credits However, we will provide the following " grace p Baeriod." If
youpa id the New Balance on your previous 0ing slaterrmnt by the Payrtent Duo Date shown on that statement and yyoou pay the Flew lance by
the Payment Due Date on this statement, we. will not impose Periodic Finance Charges on new purchases, that is, purchase fast appppewarrin?g on this
statement Otherwise, you will receive a billing statement next month that Includes Periodic Finance Charges on those new purchasha.There is no
grace period on balance transfers or cash advances.
We sort your transactions into roups of purchases, cash advances, and balance transfers and then further sort the transactions within each group by
their Annual Percentage Rate. C example purchases subject to aomotional rate and purchases subject to a standard rate world be separate
groups. We refer to these groups as Uansa 6i ca ies At the end of each btl8 r we compute balances and Periodic Finance Charges for
each day of the billin per fad for each transaction We use the follow"' tpn to compute Periodic Finance Charges for each transaction
category. Average Der7y Balance x number of da ys inthe billing period x Daily Rate (" the finance charge summary on your statement for
these amounts) Then we add up the Periodic Finance Charges for each transaction category to pet the total Periodic Finance Charges for your
Account The Average Dairy Balance is shown as zero if, because of the grace period, no Periodic Finance Charges apply to the balance in a
.
transaction category
We use the two-cycle average, daily balance (including new transactions) method of calculating the balance upon which we impose Periodic Finance
Charges. This means it you id not pay the New Balance shown on the biling statement you recei?d duffp th e previous bdknp period by the
Payment Due Date shown on that statement, we will impose Periodic Finance Charges on now purchases that. find appeared on that b ling statement,
as well as new purchases that firs appear on the current balling statement, unless we already imposed Periodic Finance Charges on the purchases on
your previous billing statement
We compute the Avers Daily Balance for each transaction categorryy by adding up all the daily balances in a billin period fo a transaction catteeggorryy
and divitlingg th e total Ogye the number of days in the billing cycle. Yye compute the dairy balance for each Ua category on each day by lira
adding the Tollowing to the previous day's daily balance. transactions made that day, fees charged that derv anddic Finance Charges accrued on
the previous day's dais balance; and by then Si am credits and payments that are a?dpYed against the !>rdence of the transaction category
on that day. In caleulafmgp the daily balance fo Phebillmg?perlod bidingp period, we consider the " s day's ndhr bbance" to have been zero on the
first derv of the billing p6riod d a transaction is our licetunt after the close of ht a b'iIirhp period fin which it occurs, we will treat the
transaction as having occurred on the firs day of in which it is posted to your Account
All fees charged to your Account are added to the standard purchase transaction category with the exception of Cash Advance Transaction Fee
Finance Charges which are added to the applicable cash advance transaction category an Balance Transfer Transaction Fee Finance Charges which
are added to the applicable balance transfer transaction category. When the special rate expires, we move the unpaid balance of the balance transfer
and the Balance Transfer Transaction Fee Finance Charges-to -the standard purchase transaction category. However, if the special rate has been
terminated under the Default Rate Plan, we leave the unpaid balance of the balance transfer and the Balance Transfer Transaction Fee Finance
Charges in the applicable transaction category until the special rate would have expired.
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For TOD (Telecommiudcatioris Device for the Deaf) assistance, please call 1-900-347-7449.
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.
(Signature)
WWR # 6413764
MARY P FULTON
6011002439506619
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SHERIFF'S RETURN - REGULAR
CASE NO: 2008-02687 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DISCOVER BANK
VS
FULTON MARY P
MICHAEL BARRICK
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
FULTON MARY P
the
DEFENDANT , at 0010:35 HOURS, on the 6th day of May 2008
at 6354 MERCURY DRIVE
MECHANICSBURG, PA 17050
MARY MOLNAR
by handing to
ADULT DAUGHTER OF DEFENDANT
a true and attested copy of COMPLAINT & NOTICE together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 11.00
Affidavit .00
Surcharge 10.00
Postage .41
-5//V/6 P C?, ? 39.41
Sworn and Subscibed to
before me this day
So Answers:
R. Thomas Kline
05/07/2008
WELTMAN, WEINBER S
By
uty Sheri
of A. D.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
MARY P FULTON
Defendant
No. 08-2687-CIVIL
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#6413764
Judgment Amount $ 11,081.56
THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
L
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
MARY P FULTON
Defendant
TO THE PROTHONOTARY:
Civil Action No. 08-2687-CIVIL
PRAECIPE FOR DEFAULT JUDGMENT
Kindly enter Judgment against the Defendant, MARY P FULTON above named, in the default of an
Answer, in the amount of $11,081.56 computed as follows:
Amount claimed in Complaint $9,581.56
Interest from date of judgment
at the legal interest rate of 6.00% per annum
Attorney's fees $1,500.00
TOTAL $11,081.56
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. r ,
William T. Molc squire
PA I.D.#47437
Weltman, Weinberg & Reis Co., L.P.A.
1400 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
W WR#6413764
Plaintiff's address is:
c/o Weltman, Weinberg & Reis Co., L.P.A.,1400 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219
And that the last known address of the Defendant is: 6354 MERCURY DR, MECHANICSBURG,PA 17050
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No. 08-2687-CIVIL
MARY P FULTON
Defendant
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the following
Order or Jud ment was entered against you
on /m 07 U
(xx) Assumpsit Judgment in the amount
of $11,081.56 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:
PR HONOTA TY)
MARY P FULTON
6354 MERCURY DR
MECHANICSBURG,PA 17050
Plaintiffs address is:
c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 76 Avenue, Pittsburgh, PA 15219
1-888-434-0085
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
MARY P FULTON
Defendant(s)
IMPORTANT NOTICE
TO: MARY P FULTON
6354 MERCURY DR
MECHANICSBURG,PA 17050
Date of Notice: Oq Q g
WWR#: 06413764
Case # i1L2L,u_+ `CIVIL
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: ? 1??wad U..o'L-'a?.?.c ---
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
DISCOVER BANK
Case no: 08-2687-CIVIL
Plaintiff
vs.
MARY P FULTON
Defendant
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.
Affant 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.
Affant further states that based upon investigation it is the affiant's belief that the Defendant, MARY P
FULTON is not in the military service.
Affant further states that this belief is supported by the attached certificate from the Defense Manpower Data
Center (DMDC), which states that the .Defendant, MARY P FULTON is not in the military service.
Further Affiant sayeth naught.
AFFIANT 2
SW RN O AND SUBSCRIBED in my presence this 36 day
of 2.
ARY PU C
cii!'i 0;
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.
Recgsuest for Military Status
Department of Defense Manpower Data Center
Military Status Report
Pursuant to the Servicemembers Civil Relief Act
Page 1 of 1
SEP-29-2008 10:39:48
Last Name First/Middle Begin Date Active Duty Status Service/Agency
FULTON MARY 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
y6t
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.html
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: WVIASRPMXT
https://www.dmdc.osd.mil/scra/owa/scra.prc Select 9/29/2008
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WELTMAN, WEINBERG & REIS CO., L.P.A. fC
I rte, l y i
BY: Sarah E. Ehasz, Esquire Attorney for Plaintiff(412 FEB 2 7
I.D. No.86469 I'l, li
436 Seventh Avenue, Suite 1400 '-U"BERLAND COUNTY Y
Pittsburgh, PA 15219 PENNS YLVAt?1JA
Phone: 412.434.7955
Fax: 412.434.7959
File # 6413764
DISCOVER BANK
Plaintiff
CUMBERLAND County
Court of Common Pleas
vs.
NO. 08-2687 CIVIL
MARY P FULTON
Defendant(s)
PRAECIPE FOR SATISFACTION OF JUDGMENT
TO THE PROTHONOTARY:
Please kindly Satisfy the Judgment of the above-captioned matter upon the records of the
Court and mark the cost paid.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By
:f?
Sarah E. Ehasz,
Attorney for Piz
Sworn to and subscribed
Before me the ZZ day of ruti , 2012
10? .1-1
' , / (2L
N ARY PU T
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal i
Mayne A. Jones, Notary Public
y City of Pittsburgh, Allegheny County !{
My Commission Expires June 29, 2014
Mkiw'brie, Pe:insvlvanla Association of Notaries
Q A '%R. So 1-A
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