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Home My WebLink About09-2167IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: O9- oZ.lID7 0-wit Terw VS. ANTONIA LOUDERMILK Defendant COMPLAINT IN CIVIL ACTION FILED ON.BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,412524 WELTMAN, WEINBERG &IREIS CO., L.P.A. 436 Seventh Avenue, (Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 07303988 C A Pit JLI IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No ANTONIA LOUDERMILK 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 ages, 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 TELEPHONEITHE 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 Now Albany Rd, New Albany, OH 43054. 2. Defendant is adult individual(s) residing at the address listed below: ANTONIA LOUDERMILK 4 COUNTRY SIDE DR CARLISLE, PA 17013 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXX8718 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 20, 2009 , in the amount of $6032.70 5. Defendant is in default by failing to make payment's 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 $1000.00 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 , ANTONIA LOUDERMILK INDIVIDUALLY 'in the amount of $6032.70 with interest at the legal rate of 6.000% per annum from date of judgment plus attorneys' fees of $1000.00 , and costs. James c warwroaz,4l5L4 WELT WEINBERG REIS CO., L.P.A. 436 S th Avenuei,, Suite 1400 Pitt shukgh, PA 15!,219 (41V34-7955 FAX-338-7130 073 C A Pit J1,I 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. VIJ%rv CK CARb $6,032.70 1 $6,032.70 08 SDSN6A01 0005417 ANTONIA LOUDERMILK 4 COUNTRY SIDE DR CARLISLE PA 17013-8419 Payment Due Date DUE IMMEDIATELY Address, e-mail or telephone change? Print change in space above, or go to Discover.com. Print your e-mail address to receive important Account information and special offers. _-..__ .-.1 . .,..., Enter Amount Enclosed Below $1 -? Will your payment get to us on time? Pay your bill online and your payment can be made to your account on the some day. Visit Discover.cons/payments today. PO BOX 6103 ?i?ur??n???ur?nlu.1r11! CAROL STREAM IL 60197-6103 {1ilniir,11111111lulu1i1111ur,))))r,r,1)111fr,u111niu)l 000001986458588097507060327000000000603270 Discover More Card Account Summary Closing Date: January 8, 2009 Page 1 of! 1 Account number ending in 8718 Previous Balance $6,032.70 Payment Due Date February 7, 2009 Payments And Credits 0.00 Minimum Payment Due $6,032.70 Purchases + 0.60 Credit Limit $5,000.00 Cash Advances + 0.60 Credit Available $0.00 Balance Transfers + 0.40 Cash Credit Limit $0.00 Finance Charges + 0.00 Cash Credit Available $0.00 New Balance $6,032.70 Cashback Bonus® C6shbdck_Bonus?ID-Aniiiversaiy - - _ _ Date: October 8 Opening Cashback Bonus Balance $ 0 New Cashback Bonus Earned ± Cashbock Bonus Balance $ 0 Available to- Redeem - - $ - _ . _ .. Q How Can We Help You? 1 • Visit Dittowr.com to pay your bill for no cost, view ur latest Account information, *am and redeem rsward3 and ;It's your choice - 3 ways to help 2. Call 1.800-DISCOVER (347.2683) for fast, easy selRservi, options or to speak with a Customer Service Account Mar Please have your Discover Card available. 1 Write us at Discover Card, PO Box 30943, For TM (assistance for hearing impaired) see reverse side Salt Lake City, UT 84130 EXHIBIT ;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: 8 days Purchases $0 0.07942% 28.99% F 28.99% $0 none Cash Advances $0 0.07942% 28.99% F 28.99% $0 $0 :,Balance Transfers $0 0.07942% 28.99% F 28.99% $0 $0 previous billing period: 26 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 Important Information. If there is more than one page to this billing statement, see the back of See Vow Cardmaaber AWeement. Your Cardmember Agreement contains all the terms of your page for additional important information. Lost or stolen suds. Report immediately! Call 1400447-2883. BI81ny RVO Surnesery. In Case of Errors or Questions About Your Bill: if you think your bill is wrong, or if you need more information about a Uansactidn on your bill, write to us on a separate sheet of paper at Discover Card; PO Box 304211 Salt Lake City, UT 84130.0421, as soon as possible. We must hear from you no later than 60 days after we sent you the first bill on which the errr 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. • esscriibe the error and explain, if you can, why you believe there is an error. If you need morel information, describe the item you are unsure You do not have to pay any amount in question while we are investigating, but you are still o ligated 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 any action to collect the amount you question. Special Rule for Credit Card Purcimes: If you have a problem with the quality of goods or rvices that you purchased with a credit card, and you have tried in good faith to correct the problem with the merchant, You maw not have pay the remaining amount due on the goods or services. You have this protection only when the purchase price was more than $ 5y0 and the urcflase was made i your home state or within 100 miles of your mailing address. (If we own or operate the merchant, or if we mailed you the ad cement for the goods or services, all purchases are covered regardless of the amount or location of purchase.) Payments. Send only your payment and the top portion of this statement in the envelope ded. Do not send cash: By sending your check as described above, you authorize us to use information on your check to make an electronic fp und ansfer from your account at the financial institution indicated on your check or to process the payment as a check transaction. If payment is proc seed as an electronic f nit transfer, the transfer will be for the amount of the check. When we use information from your check to make an electro k fund transfer, funds tray 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. The processing of your payment mayy be delayed if you send cash, correspondence or other item with your ppaaymentL If I send the payment to any other address or if you use an envelope other than-lhe-one-Eioviced -Payments received on or fter 1 P. Monday thrFridayor on a weekend or bank holiday will be posted to your Account as of the next business day. If you have misplaced your envelope Seur payment to Discover Bank, PO Box 6103, Carol Stream, It. 60197-6103. Please allow 7.10 days for delivery. If your payment is returner) , we reserve the right to resubmit it as an electronic debit You can pay your minimum payment or a greater amount over the telephone, and you can set up automatic payments. Call us at 1-800-347-2683. You will need this statement and your bank account information. You must ensure that sufficr t funds are available i" your bank account, and all transactions must comply with U.S. law. You will be asked to provide the first 5 digits of r account statement lip code. By entering those numbers as your electronic signature. You will be agreeing to this authorization to aloes us an your bank to deduct each payment you authorize from your bank account, and to initiate debit or credit enures to your bank account, as appli able to correct an error in the processing of such payment You must tell us the amount of each payment, or you can select an amount such a he Mnimum Payment Due or the New Balance on each statement You can cancel a payment however we must receive notice at least three busi ess days in advance of he scheduled payment You may notify us by phone at 1.800.347.3683 or by mail at address listed in the previous para0rap . If your payments may vary in amount we will tell you on each monthly statement when your payment will be made and how much it will be. Your Automatic payment amount may be lass than indicated on the monthly statement based on credits or payments applied during the billing cycle. CroM Repor". We may report information about your account to credit bureaus. Late paV missed payments, or other defaults on your account may be reflected in your credit report We normally report the status and payment h ry of your Account W credit reporting agencies each month. If you believe that our report is inaccurate or incomplete please write us at the followin address: Discover Card, PO Box 116, Wilmington, DE 19850.5316. Please include your name, address, home telephone number and Account num r. 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 pa your entire New Balance, by making payments or receiving credits. H ever, if you pale the New Balance on your previous billing statement by the Payment Due Date shown on that statement, and you pay-the New Balance by the Payment Due Date on your current billing statement, we will not impose Periodic Finance Charges on new purchases, that is, purchases first appearing on the current statement We call this the grape period. Otherwise,' You; will receive a billing statement next,month that includes Periodic Finance Charges on those new purchases. There is no grace period on balance transfers or cash advances. We sort your transactions into groups of purchases, cash advances, and balance transfers and then further sort the transactions within each group by their Annual Percentage Rate. For example, purchases subject to a promotional rate and pur ases subject to a standard rate would be se rate F roups. We refer to these groups as transaction categories. At the end of each billing period, a compute balances and Periodic Finance Charges or ?!a6 olay of !i-r, billing p 4rJ 0 each iransamicn "'.egoly. We ute the f6irayin• P,.Y3 as to compute Periodic Finance Charges-for each transaction category. Average Daily Balance x number of days in the billin period x daily P nodic Rate. You may refer to the finance charge summary on your billing statement for these amounts.) Then we add up the?eriodic Finance harges for each transaction category, to get the total Periodic Finance Charges for your Account The Average Daily Balance is shown as zero if, beta se of the grace period, no Periodic Finance Charges apply to the balance in a transaction category. We use the two-cycle daily average balance (including new transactions) method of calculating a balance upon which we impose Periodic Finance Charges. This means if you did not pay the New Balance shown on the billing statement received during the previous billing period by the Payment Due Date shown on that statement, we will impose Periodic Finance Charges on new p rchases that first appeared on that billing statement, as well as new purchases that first appear on the current billing statement, unless we already i posed Periodic Finance Charges on the purchases on your previous billing statement We compute the Average Daily Balance for each transaction category by adding up all the dairy lances in a billing period for a transaction category and dividing the total by the number of days in the billing cycle. a compute the daffy balance for each transaction category on each day byTirsf adding the Tollowing to the previous day's daily balance: transactions made that day, fees cha ged that day and Periodic Finance Charges accrued on the previous day's daily balance; and by then subtracting any credits and payments that are applied against the balance of the transaction category on that day. In calculating the daily balance for the first day of the, billinperiod, we consider the "Previous days balance" to have been your-balance for each transaction category on the last day of your previous billing period. If a transaction is posted to your Account after the close of the billing period in which it occurs, we will treat the transaction as having occurred on the first day of the billing period in which it is posted to your Account All fees charged to your Account are added to the standard purchase transaction categ ith the exception of Ca$h Advance Transaction Fee Finance Charges which are added to the applicable cash advance transaction category andBala ce Transfer Transaction Fee Finance Charges which are added to the applicable balance transfer transaction category. When a special balance tran er rate expires, we move the unpaid balance of the balance transfer and the Balance Transfer Transaction Fee Fnance Charges to the standard p rchase transaction Category. However, 9 the special rate has been terminated under the Default Rate Plan, we leave the unpaid balance of the baIan a transfer and the Balance Transfer Transaction Fee Finance Charges in the applicable transaction category until the special rate would have expired.' For TOO (Telecommunications Device for the Deaf) assistance, please call 1400-347-7449. v Z Z a V VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §1904 relating to unsworn falsifications to authorities, that she is Beth Bohac (Name) Accounts Manager of DFS Seryiues LLC , plaintiff herein, that (Title) (Company) she is duly authorized to make this Verification, and that the facts set forth in the fotegoing Complaint in Civil Action are true and correct to the best of her knowledge, information and belief. (Signature) WWR# 7303988 Antonia Loudermilk '6011002464138718 FILENCYXE OF TIE FROTHIONTARY 2009 AP° -6 P11 3. 14 t ?, "18.5o Pty A ??.?` 3gto$atal ?? ?a33a3 R Thomas Kline Sheri Ronny R Anderson Chief Deputy Edward L Schorpp Solicitor Jody S Smith Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/13/2009 04:00 PM - Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on April 13, 2009 at 1600 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Antonia Loudermilk, by making known unto Antonia Loudermilk personally, at 4 Countryside Drive, Carlisle, Cumberland County, Pennsylvania, 17013, its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $32.50 April 14, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF 961 Sher f f Docket No. 2009-2167 Discover Bank v Antonia Loudermilk Sheriffs Office of Cumberland County DISCOVER BANK Plaintiff vs. ANTONIA LOUDERMILK Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION No: 09-2167 CIVIL TERM PRAECIPE FOR DEFAULT 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 100 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 07303988 C A Pit JLI Judgment Amount $7032.7011 DISCOVER BANK Plaintiff VS. ANTONIA LOUDERMILK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Civil Action No. 09-2167 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONTARY: Kindly enter Judgment against the Defendant ANTONIA LOUDE ILK above named, in the default of an Answer, in the amount of $7 32.70 computed as follows: Amount claimed in Complaint $6032.70 Less payments / adjustments made $0.00 Attorney's fees $1000.00 TOTAL $7032.70 I hereby certify that appropriate Notices of Default, as been mailed in accordance with PA R.C.P. 237.1 on the dates ii Notices. attached have idicated on the WELTMAN, WEINBERG & REIS COQ, L.P.A. By: James C. 07303988 Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A. Pittsburgh, PA 15219 And that the last COUNTRY SIDE DR CARLISLE, PA 17013 Pit JLI 6 Seventh Avenue,?Suite 1400 address of the D fendant is: 4 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 09-2167 CIVIL TERM ANTONIA LOUDERMILK NON-MILITARY AFFIDAVIT The undersigned, who first 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 i the affiant's belief that the Defendant , ANTONIA LOUDERMILK 4 COUNTRY SIDE DR CARLISLE, PA 17013 is not in military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMSC), whi h states that the Defendant , ANTONIA LOUDERMILK 4 COUNTRY SIDE DR CARLISLE PA 17013 is not in the military service. Further Affiant sayeth naught. SWORN TO AND S 7,3 IBED in my presence this 13 day of v A A I ZOO Notarial Se I Wendy L. Gault, No ry Public City Of Pittsburgh, Alleg ny County My Commission Expires July 15, 2010 Member, Pennsyivania Asso :iation of Note IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff Case No. 09-2167 CIVIL TERM VS. ANTONIA LOUDERMILK Defendant IMPORTANT NOTICE TO: ANTONIA LOUDERMILK 4 COUNTRY SIDE DR CARLISLE, PA 17013 Date of Notice: -151 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRI EN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSE OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM HE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YO MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT H FH A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA. 17013 (717)249-3168 WELTMAN, WEINBERG & REIS CO., L.P.A. By: / -- Matthew Urban P.A.I.D.# 90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 7303988 A PIT T4S Request for Military Status Department of Defense Manpower Data Center Military Status Report V1 Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 MAY-27-2009 06:13:43 -< Last Name First/Middle Begin Date Active Duty Status Service/ A gency LOUDERMILK ANTONIA Based on the information you have furnished, the DMDC does not pos information indicating that the individual is currently on active duty. ess any 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. I 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 in; Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hui of "does not possess any information indicating that the individual is currently on active duty" responses a small error rate. In the event the individual referenced above, or any family member, friend, or represe manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you encouraged to obtain further verification of the person's active duty status by contacting that person's Mi "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail v 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 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 points-of-contact. See: http_//www.defenselink.mil/faaq/nis/PC09SLD_ R.htm_1 WARNING: This certificate was provided based on a name and Social Security number (SSN) prov Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: ENIFVWLXL V tains the Defense igibility for military 0 USCS Appx. §§ lreds of thousands and has experienced tative asserts in any .re strongly itary Service via the obtain this you can Service SCRA by the requester. https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 5/27/2009 RLFD-; !=r. "'E OF THE P;2 0 0 9 JJ d 11 PM 12: 59 UINTY 4 ?. 'sl*vlj' jATry e,v-* 40(A343 P-T* aa(o sss IJA.e,L. Aac+wL4 I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. ANTONIA LOUDERMILK Civil Action No. 09-2167 CIVIL NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee TERM You are hereby notified that the fallowing order of Judgm nt was entered against you on It`07 (xx) Assumpsit Judgment in the amount of $7032.70 plus cots. ( ) Trespass Judgment in the amount of $ plus cots. ( ) If not satisfied within sixty (60) days, your motor ehicle operator's license and/or registration will be suspe ded by the Department of Transportation, Bureau of Traff c Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothanot By: ANTONIA LOUDERMILK 4 COUNTRY SIDE DR CARLISLE, PA 17013 DE Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, ISuite 1400 Pittsburgh, PA 15219 (412) 434-7955 T r IN THI/ COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff rs. ANTONIA LOUDERMILK Defendant TD BANK, Garnishee, No. 09-2167 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION AND ENTER TT IN TAE JUDGMENT INDEX (BANK ATTACHMENT ONLY) cn '~ l " ` `.~ Y ! ~, `' "-. ~ c~-. ~ ~; _ -- ~ rn 1 FILED ON BEHALF OF r ~- cst ;__s , ~ Plaintiff y.. x,. , -_ ~- {'' " ~ , _ ~~: COUNSEL OF RECORD OF :~ ,-. ~: `•~' ~__ THIS PARTY: -~ ~'` ` c.r~; =r' --< Matthew D. Urban, Esquire PA LD. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#07303988 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DNISION D~fSCOVER BANK Plaintiff vs. Civil Action No. 09-2167 CIVIL TERM A3a1TONIA LOUDERMILK ~,~p(o Cif ~ furl ig(e P~4 l~013 Defendant TD BANK, 38a ~ W . L.inedn fhghwa~.~, Downinginwn , PA 1°1336 Garnishee PRAECIPE TO INDEX WRIT OF EXECUTION AND ENTER IT IN THE JUDGMENT INDEX TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CHESTER County: 2. against ANTONIA LOUDERMILK, Defendant 3. against TD Bt~NK, Garnishee 4. and enter this writ in the judgment index (a) against ANTONIA LOUDERMILK, defendant, and (b) against TD BANK, as garnishee , as a lis pendens against real property of the defendant in the name of garnishee as follows: Any and/or all personal ~rogerty belonging to the defendant(s) in possession of the garnisheeL) 5. Judgment Amount Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): ~ o'I`4~.6o P P AT't"~ 3a. so CBF 78. Sa ~~ l'~F . oo '' a .SD '~ 15a.oo - PD A'TT`~ $ 7,032.70 $ 411.72 $ 7,444.42 WEL N, W INBERG & REIS ~ / / atthew D.~ban, Esquire PA LD. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 $ a . oo IJue~ • so ccr ~~ v~aa~aa -- ~~ a~l3logs Ches~ler ~ou-r~y (~ri1~-o-P ~ J~~~~ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-2167 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CHE5TEl2 COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From ANTONIA LOUDERMILK, 206 Faith Circle, Carlisle, PA 17013 (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: TD BANK, 3821 W. Lincoln Highway, Downingtown, PA 19335 Any and/or all personal property belonging to the Defendant in the possession of the Garnishee 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 $7,032.70 L.L. $.50 Interest -- $411.72 Atty's Comm % Due Prothy $2.00 Atty Paid $152.00 Other Costs Plaintiff Paid Date: 6/15/10 ell, Pro onotary (Seal) By; Deputy 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