HomeMy WebLinkAbout08-7508
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA), NA - C J ?
Plaintiff No: 7so8 (21 (1 LT{ GZyl..
'STS .
STEVE W CLARK
COMPLAINT IN CIVIL ACTION
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
07019780 C N Pit CFR
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
VS.
STEVE W CLARK
Defendant
Civil Action No
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, CAPITAL ONE BANK (USA),NA is a corporation with offices
at 15000 CAPITAL ONE DRIVE RICHMOND , VA 23238 .
2. Defendant is adult individual(s) residing at the address listed
below:
STEVE W CLARK
1392 LOWTHER RD
CAMP HILL, PA 17011
3. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXX0517 .
4. Defendant made use of said credit card and has a current balance
due of $4044.29 , as of October 29, 2008 .
5. Defendant is in default by failing to make monthly payments when
due. As such, the entire balance is immediately due and payable to
Plaintiff .
6. Plaintiff is entitled to the addition of interest at the rate of
27.100% per annum on the unpaid balance from October 29, 2008 . A copy
of Plaintiff's STATEMENT is attached hereto, marked as Exhibit "1" and
made a part hereof.
7. 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 , STEVE W CLARK , INDIVIDUALLY , in the amount of
$4044.29 with continuing interest thereon at the rate of 27.100% per
annum from October 29, 2008 plus costs.
BERG & REIS CO., L.P.A.
venue, S uite 1400
7FAX:22 ro t,42524
A 15219
55
-7130
Pit CFR
This law firm is a debt collector attemp g to collect this debt for
our client and any information obtained till be used for that purpose.
FINANCE
Previous Balance P"nts & Credits CHARGE Transactions New Baratta Minimum Payment Due Date
$2,738 02 - $0 00 + $68 63 + $78 00 = $2,884 65 $384 65 Oct 05, 2007
Aug 10, 2007 - Sep 10, 2007 Page 1 of 1 PUASe MY AT LW7 7141 MOA I
sh
Visa Platinum Account
130ST221-?t81-0517
Your Account Information
TOTAL CREDIT LINE $2,500 00
TOTAL AVAILABLE CREDIT $0 00
CREDIT LINE FOR CASH $2.50000
AVAILABLE CREDIT FOR CASH $0 00
Finance Charges (Please see reverse for rmporeot nfrmalow)
Balance ra Periodic ding nNANCE
appled b rate APR CHARGE
Purchases $2,780 78 0 07712% D 2815% $6663
Cash $000 0 07712% D 2B 15% $000
ANNUAL PERCENTAGE RATE applied this period. 25.15%
® At Your Service 1400403.MT
To cal COWNIF Relate or to report aknt rst*n card
® OWN One Bank P O Bos M184 Chedotte, NC 18272-0684
A Ssnd inquires to.
Capra Ore P.0 BII 30185 Seit take City, UT 84130-0285
® Have a question about a charge on your statement?
please refer to the Billing Rights Summary m the be& of
yar statement or wart
You're beMd by three payments That means you are trmporarly unable to mace new purdiases or pet ca
advances. But you an room !rout Capita One ds9rn9 Prtoile9es rid MM Your account back MW good
standing by paying t* mount due on your statement if yt.ye having rnr+aat aRfudbes and youVe feeling
Overwhemed - we ward to hap. Give one or our associates a call at 1800 9% 6600 You'd be surprised what we
an do togettr to work this out
pay me Credits & Ad ustmerb
Trartsadbns $3900
1 03 SEP PAST DUE FEE $3900
2 1D SEP OVERLIMIT FEE SEP 10, 2001
Under temp previously disclosed to YOU, a" a rI Of your A"al Percentage Rates (APRs) have bean
increased anal your amount
uss_ pool due b"m " past `12 boiling CYd@s I your es exNnded the drshon of ft Increased rats ioRionard r Rawe receive
ylyour ? nen'mrrll morlThy payment mot ant on urea to 12 consecutive bang cycles, the accountwd be reviewed for a
possible return tD your Non-Irdrodudry APR
You were asseasad a past due fee because your mrumum payment was not received by the due dale To avoid
this fee in The future, we recommend that you allow at least 7 busnesa days for your mnmurn payment to reach
Capra One
?./?s asv?
C
910 PAGE
oiDM6056
6056 506 1 ui 1 070
PLEASE RETURN PORTION BELOW WITH PAYMENT OR LOG ONTO W WW CAPITALONE COM TO MAID: YOUR PAYMENT ONLINE
.' f?0W I what's in your w?1e17"
New Balance Minimum Payment Due Date
C$2,884 65 $384 65 Oct 05, 2007
PLEASE PAY AT LEAST
THIS AMOUNT
0 4305722143640517 09 2884650071000384651
Amount Enclosed C==
Capital One Bank 'r'rrlrrl rlle1r?Irelr?
P.O. Box 70884
Charlotte. NC 28272-0644
1 111111111 11n1e1aIloilo Isell
Account Number. 4305-7221-4364-0517
Please print address or phone number changes below using blue or black ink
address
Heine Phone AAemate Phone
E-mad address Q
#9025473169182392# MAIL ID NOMDER
STEVE W CLARK
1342 LOWTHER RD
CAMP HILL, ph 17011-7534
7019780 Please write your account number on your check or money order made payable to capital one Bank and mall with this coupon in the enclosed envelope
CAPITAL ONE BANK (USA), N.A.,
Plaintiff,
V.
STEVE W CLARK
Defendant(s).
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating
to unworn falsification to authorities, that he/she is an authorized agent of CAPITAL ONE
BANK (USA), N.A., Plaintiff herein, and that 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.
Dated: A4%0&- S ame S' more
A049
WELTMAN, WEINBERG & REIS CO., L.P.A.
Ek. ?
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c-? IM
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-07508 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CAPITAL ONE BANK USA NA
VS
CLARK STEVE W
MARK CONKLIN
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
CLARK STEVE W
the
DEFENDANT , at 1010:00 HOURS, on the 3rd day of January , 2009
at 1392 LOWTHER ROAD
CAMP HILL, PA 17011
KRISTI CLARK, 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
Sworn and Subscibed to
before me this
So Answers:
18.00
13.50
.00
10.00 R. Thomas Kline
.00
41.50 01/05/2009
WELTMAN WEINBERG REIS
By.
day Depu y heriff
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA), NA
Plaintiff
vs.
No.08-7508 CIVIL TERM
STIPULATION OF THE PARTIES FOR
PAYMENT AND FOR THE ENTRY OF
JUDGMENT BY CONSENT
STEVE W CLARK
Defendant
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
Matthew D. Urban, Esquire
PA I.D. #90963
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#07019780
$4,418.56
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA), NA
Plaintiff
VS. Civil Action No. 08-7508 CIVIL TERM
STEVE W CLARK
Defendant
PRAECIPE FOR JUDGMENT BY CONSENT
TO THE PROTHONOTARY:
Kindly enter Judgment against Defendant, STEVE W CLARK, in the amount of $4,418.56 plus
costs, based upon the consent of the parties.
CONSENTED TO:
WELTMAN, WEINBERG & REIS CO., L.P.A.,
By:
A t t /me for Plaintiff
STEVE W CLARK,
By:
De n nt
WWR#07019780
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA), NA
Plaintiff
vs. Civil Action No. 08-7508 CIVIL TERM
STEVE W CLARK
Defendant
STIPULATION OF THE PARTIES FOR PAYMENT
AND FOR THE ENTRY OF JUDGMENT BY CONSENT
TO THE PROTHONOTARY:
Kindly enter Judgment in favor of Plaintiff and against the Defendant, STEVE W CLARK,
above-named, in the amount of $4,418.56 pursuant to the Stipulation of the Parties for Payment and for
the Entry of Judgment by Consent, as follows:
Defendant admits indebtedness to Plaintiff in the amount of $4,418.56 with continuing
interest thereon at a rate of 6.00% per annum plus costs from Date of Judgment.
2. To secure the repayment of said indebtedness, Defendant agrees that Judgment by
Consent will be entered in favor of the Plaintiff and against the Defendant, STEVE W CLARK, in the
amount of $4,418.56 plus continuing interest thereon at the rate of 6.00% per annum from Date of
Judgment and costs.
Plaintiff agrees not to execute on its Judgment so long as Defendant causes to be
delivered to Plaintiff the following payments in full by 12:00 NOON on the following dates:
(a) $155.00 due by June 26th, 2009;
(b) $155.00 due on the 26t' day of each consecutive month thereafter until the Judgment
amount plus accrued interest and costs are paid in full.
4. All payments are to be made payable to the order of "CAPITAL ONE BANK (USA),
NA"
s
5. The first payment due under this agreement is to be received at the offices of Weltman,
Weinberg & Reis, Co., L.P.A., 436 Seventh Avenue, Suite 1400, Pittsburgh, PA 15219. All future
payments are to be mailed to the offices of Weltman, Weinberg & Reis, Co., P.O. Box 5430, Cleveland,
OH 44101-0430.
6. In the event of default, each payment received shall be first attributed to costs, interest
and then to principal.
7. Time is of the essence of this agreement and should the Defendant fail to have in the
hands of Plaintiff or Plaintiff's counsel any payment in full within five (5) calendar days of the stated due
date, then Plaintiff shall be immediately free to issue Execution as well as pursue all other remedies, in
law or in equity, to collect the full balance of the Judgment entered hereunder plus appropriate additional
interest and costs.
8. No act or omission of the Plaintiff, nor of anyone alleged to be acting on its behalf, shall
constitute a waiver, estoppel, or any other excuse for non-performance of any duty undertaken by the
Defendant in this Stipulation which the parties agree is final and complete. d ?f'
9. Intending to be legally bound, the parties set their hands and seals thk-" day of
??, 20_d"-_.
By:
Def dant, STEVE W C ARK
WELT WEINBERG & REIS CO., L.P.A.
B
Matthew D. Urban, Esquire
PA I.D. #90963
WELTMAN, WEINBERG & REIS CO.,
L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR No. 07019780
T"!E Li i ?+1
OF TH OV
2009 AJQ -7 Pli 0 I
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA), NA
Plaintiff
vs. Civil Action No. 08-7508 CIVIL TERM
STEVE W CLARK
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 $4,418.56 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
( ) Default
( ) Verdict
( ) Arbitration
( ) Award
(XX) By Consent
Prothonotary
STEVE W CLARK
1392 LOWTHER RD
CAMP HILL, PA 17011
By:
PRO ONOTARY (OR DEPU bXA
I . ? w
F1LED- ?Ji!uE
THI-
2 (0 MAR -8 PM 2: 31
J, i
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA), NA
Plaintiff
vs.
STEVE W CLARK
Defendant
McTp_.o 6W4. Vf I A
COMMERCE BANK,
Garnishee,
"iJ
U4.50 PO A-TTY
41• so CBF
18.50
Iq.00
a.so
1101 • 00 - Rb AlT`/
No. 08-7508 CIVIL TERM
PRAECIPE FOR WRIT OF EXECUTION
(BANK ATTACHMENT ONLY)
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
Matthew D. Urban, Esquire
PA I.D. #90963
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#07019780
L.L
5 D.v.56 Pk -11,
I1 %46
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA), NA
Plaintiff
vs. Civil Action No. 08-7508 CIVIL TERM
STEVE W CLARK
Defendant
COMMERCE BANK,
Garnishee
TO THE PROTHONOTARY:
PRAECIPE FOR WRIT OF EXECUTION
Kindly issue a Writ of Execution in the above matter...
1. directed to the Sheriff of CUMBERLAND County:
Lt,Pc` 1'70 r
2. against STEVE W CLARK, Defendant
M ETRA
3. against eE+fM£ReC-BANK, Garnishee
301o?1'NAF?c?+2?+'
4. Judgment Amount C&t f sjl f( Pk (7 D 1'1 $ 4,418.56
Less payments of $ 1,033.50
Interest $ 122.69
Costs
SUBTOTAL:
Costs (to be added by Prothonotary):
WELTMAN, WF?NBERG & REIS CO., L.P.A.
By: / .-
Matthew D. Urban, Esquire
PA I.D. #90963
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Sev6Wh Avemm
Pittsburgh, PA 15219
(412) 434-7955
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 08-7508 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due CAPITAL ONE BANK (USA) NA, Plaintiff (s)
From STEVE W. CLARK, 1392 Lowther Rd, Camp Hill, PA 17011
(1) You are directed to levy upon the property of the defendant (s)and to sell
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
METRO BANK f/Wa COMMERCE BANK, 3201 Trindle Road, Camp Hill, PA 17011
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 $3,385.06
Interest -- $122.69
Atty's Comm %
Atty Paid $161.00
Plaintiff Paid
Date: 3/8/10
(Seal)
L.L. $.50
Due Prothy $2.00
Other Costs
2-&6V
David uell, Proth otary
By:
REQUESTING PARTY:
Name MATTHEW D. URBAN, ESQUIRE
Address: WELTMAN, WEINBERG & REIS CO, LPA
1400 KOPPERS BUILDING
436 SEVENTH AVENUE
PITTSBURGH, PA 15219
Attorney for: PLAINTIFF
Telephone: 412-434-7955
Supreme Court ID No. 90963
Deputy
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLb5NI, T;
CIVIL DIVISION -T4r -i
c-n
CAPITAL ONE BANK. (USA), NA
A_} _V .'.
Plaintiff No. 08-7508 CIVIL TERM ? 43
' ?
1
C)'
_
Answers _Io
vs. INTERROGATORIES IN ATTACHMENT
COMMERCE BANK
STEVE W CLARK
Defendant
and
COMMERCE BANK
Garnishee FILED ON BEHALF OF:
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
Matthew D. Urban, Esquire
PA I.D. 490963
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
W WR#07019780
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA), NA
Plaintiff
vs.
STEVE W CLARK
Defendant
and
COMMERCE BANK
Garnishee
Civil Action No.: 08-7508 CIVIL TERM
TO: COMMERCE BANK Suggested Reference No.: XXX-XX-9393
3201 TRINDLE ROAD
CAMP HILL, PA 17011
RE: STEVE W CLARK
1392 LOWTHER RD
CAMP HILL, PA 17011
IMPORTANT NOTICES TO GARNISHEE!
A. You are required to file answers to the following interrogatories within twenty (20) days after
service upon you. Failure to do so may result in Judgment against you.
B. Herein, the word "defendant" means any one or more of the defendants against whom the writ of
Execution is issued.
C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to
attachment which is then in the hands of the garnishee, it also attaches all property of the defendant which comes
into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For example, the
resultant liability of a Garnishee-Bank would not be measured by the balance in the debtor's account, either at the
time of service of the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited
and withdrawn during the intervening period.
INTERROGATORIES IN ATTACHMENT
1. At the time you were served or at any subsequent time did you owe the defendant any money or
were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money
or were liable to him for any reason (including finds on deposit for checking or savings accounts and certificates of
deposit)? Defendant has account 537059511 held jointly with Kristi Clark
with a balance of $620.62. Account has direct deposit (payroll)
Defendant did not receive $300 exemption.
1 a. If the answer to Interrogatory I is in the affirmative, state the following: the amount
of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof,
the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written
instruments and the present location of each of such instruments; the amount or amounts that defendant claims or
claimed that you owe or owed to him; and the nature and amount of each of such liabilities.
See answer to question 1
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.
See answer to question I
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?
See answer to question 1
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 yoir afe-Vbank 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.
See answer to question 1
8. If you are a bank or other financial institution. at the time you were served or at any subsequent
time did the defendant have funds on deposit in an account in which the funds on deposit, not including any
otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If
so, identify each account.
See answer to question 1
9. If the answer to Interrogatory I is in the affirmative, state the date the sheriff served these
interrogatories on this institution.
3/19/2010
10. If the answer to Interrogatory 1 is in the affirmative, state the date the written instrument, checking
or savings account, certificate of deposit, or other funds were frozen, restricted, or otherwise put on hold by this
institution.
See answer to question 1
1 1. If the response to Interrogatory 7 is in the affirmative are other funds comingled in the account
which are not deposited electronically on a recurring basis and which are identified as being funds that upon deposit
are exempt from execution, levy or attachment under Pennsylvania or federal law?
12. If the response to Interrogatory 1 1 is in the affirmative, state the amount of non-exempt funds on
deposit in the account-
WELTMAN, WEINBERG & REIS CO., I .P.A.
Matthew D. Urban, Esquire
PA I.D. 490963
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR907019780
By:
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 Jennifer Hilbish
(Name)
Levy Specialist of Metro Bank, garnishee herein,
(Title) (Company)
that he/she 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.
( G TURE)
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Edward L Schorpp
Solicitor
4?n??. at ?u+i?6cx??c
.?pTARY
2010 MAR 26 th 8.41
CUM?C? ? -'LINTY
Capital One Bank (U.S.A.) N.A.
vs.
Steve W Clark
SHERIFF'S RETURN OF SERVICE
Case Number
2008-7508
03/19/2010 12:04 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 19,
2010 at 1159 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies
of the within named defendant, to wit: Steve W. Clark, in the hands, possession, or control of the within
named garnishee, Metro Bank F/K/A Commerce Bank, 3201 Trindle Road, Camp Hill, Cumberland County,
Pennsylvania 17011, by handing to Nina Landis, Assistant Manager, personally three copies of
interrogatories together with three true and attested copies of the writ of execution and made the contents
there of known to her.
The writ of execution and notice to defendant was mailed on 03-25-10 to Steve W. Clark at 1392 Lowther
Road, Camp Hill, PA 17011.
SO ANSWERS,
March 25, 2010 RON R ANDERSON, SHERIFF
i Mm Cline, Deputy
i.cj cour'ySuite .^erff. Tepecso't, Ins.
r u7
?'TA?Y
2010 JUH 28 FM 12: 4b-
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
vs.
STEVE W CLARK
Defendant(s)
No. 08-7508 CIVIL TERM
PRAECIPE FOR SATISFACTION OF
JUDGMENT
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
Lyndsay E Rowland, Esquire
PA I.D. # 205520
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#7019780 CFR
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IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY., PENNSYLVANIA
CIVIL DIVISION
CAPITAL ONE BANK (USA),NA
Plaintiff
vs. Civil Action No. 08-7508 CIVIL TERM
STEVE W CLARK
Defendant(s)
PRAECIPE FOR SATISFACTION OF JUDGMENT
At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment.
WELTWN, WEINBERG & REIS CO., L.P.A.
By:
LyndsaylE Rowlan?j Esquire
PA I.D. 205520 ``
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7999
WWR #7019780
Sworn to and subscribed
before me this _-7
day of 10
-''NOTARY j?GBLIC
COMIVG"
She;;?
i,iieynsnyCcuurity
Comm?,cr
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Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
2T10 JJ-123 ;
NTY
Capital One Bank (U.S.A.) N.A.
Case Number
vs.
Steve W Clark 2008-7508
SHERIFF'S RETURN OF SERVICE
03/19/2010 12:04 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 19,
2010 at 1159 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies
of the within named defendant, to wit: Steve W. Clark, in the hands, possession, or control of the within
named garnishee, Metro Bank F/WA Commerce Bank, 3201 Trindle Road, Camp Hill, Cumberland
County, Pennsylvania 17011, by handing to Nina Landis, Assistant Manager, personally three copies of
interrogatories together with three true and attested copies of the writ of execution and made the contents
there of known to her.
The writ of execution and notice to defendant was mailed on 03-25-10 to Steve W. Clark at 1392 Lowther
Road, Camp Hill, PA 17011.
06/28/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is
returned STAYED, per request from plaintiff's attorney.
SHERIFF COST: $138.02 SO ANSWERS,
6z x
June 28, 2010 RONK'Y R ANDERSON, SHERIFF
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