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Home My WebLink About09-2579 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: OR-,16'7q 0,iiA Ter.,, VS. THERESA L TODD 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 07353546 C A Pit ABR VISION COUNTY, PENNSYLVANIA IN THE COURT OF COMMON PLEASCIF CUMBE DISCOVER BANK Plaintiff vs. THERESA L TODD 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, 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: THERESA L TODD 803 W KELLER ST MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXX9737 . 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 14, 2009 , in the amount of $10538.54 . 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 , THERESA L TODD INDIVIDUALLY , in the amount of $10538.54 with interest at the legal rate of 6.000% per annum from date of judgment plus attorneys' fees of $1500.00 , and costs. ERG & REIS CO., L.P.A. enue, Suite 1400 T?q-38 ro t,42524 15219 5 7130 Pit ABR 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. .? . "¦? 4iv,asts.54 $10,538.54 CARD -- - - Payment Due Date March 14, 2009 15 SDSN6A010004420 THERESA TODD 803 W KELLER ST MECHANICSBURG PA 17055-4029 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. Enter Amount Enc'osed Below $ Please make check payable to Discover Card. Minimum pa ment due includes a past due amount of $2,205.00. 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.com/payments today. PO BOX 6103 111 111 ill 1111 till IIIIIIIIII CAROL STREAM IL 60197-6103 000001986458155101773105385400000001053854 Discover More Card Account Summary Closing Date: February 15, 2009 page 1 of 1 Account number ending in 9737 Previous Balance $10,538.54 Payment Due Date March 14, 2009 Payments And Credits 0.00 Minimum Payment Due $10,538.54 Purchases + 0.00 Credit Limit $8,200.00 Cash Advances + 0.00 Credit Available $0.00 Balance Transfers + 0.00 Cash Credit limit $0.00 Finance Charges + 0.00 Cash Credit Available $0.00 New Balance $10,538.54 Cashback Bonus® Opening ICashback Bonus Balance $ 0.00 New Cashback Bonus Earned + 0.00 Cashback Bonus Balance $ 0.00 - -Cashback-BonusO Anniversary - - --- - - - - - - - - - - - - Availriblo-to Redeem Date: June 15 How Can We Help YOU? 1. Visit Discoveacom to pay your bill for no cost, view your p latest Account information, earn and redeem rewards and more It's your choice - 3 ways to help 2. Call 1-800-DISCOVER (347.2683) for fast, easy self-service Please have your Discover Card available, options or to speak with a Customer Service Account Manager For TDD assistance for hearing impaired) see reverse side 3. Write us at Discover Card, PO Box 30943, ( Salt Lake City, UT 84130 EXHIBIT f?- 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: 15 days Purchases $0 0.07942% 28.99% F 28.99% $0 none Cash Advances $0 0.07942% 28.99% F 28.99%, $0 $0 previous billing period: 20 days Purchases $0 0.67942% 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 each page for additional important information. See your Cardmember Agreement. Your Cardmember Agreement contains all the terms of your Account Cl) Lost or stolen cards. Report immediately! Call 1-800-847-2683. Z m BRlkig Rights Summary. In Case of Errors or Questions About Your Bill: If you think your bill is wrong, or if you need more information about a o transaction on your bill, write to us on a separate sheet of paper at Discover Card; PO Box 30421, Satt Lake City, UT 84130-0421, as soon as possible. o We must hear from you no later than 60 days after we sent you the first bill on which the error or problem appeared. You can telephone us, but o doing so will not preserve your rights. In your letter, give us the following information: °a *Your name and Account number. a *The dollar amount of the suspected error. o siDeseribe 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 investigate your question, we cannot report you as delinquent or take any action to collect the amount you question. Special Rule for Credit Card Purchases: If you have a problem with the quality of goods or services that you purchased with a credit card,, and you,have tried in goat faith to correct the problem with the merchant, you may not have to y the remaining amount due on the goods or services. You have this protection only when the purchase price was more than S50 and the purchase was made in your home state or within 100 miles of your mailing address. (If we own or operate the merchant or if we mailed you the advertisement 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 provided. Do not send cash. By sending your check as described above, you authorize us to use information on your check to make an electronic fund transfer from your account at the financial institution indicated on your check or to process the payment as a check 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 the same day we receive your payment and you will not receive your check back from your financial institution. The processing of your payment may be delayed if you send cash, correspondence or other items with your payment if you send the payment to any other address or it you use-an envelope other than the-one provided Payments received-on orafter l PM-Monday-through Friday or-on a v430end or bank holiday will be posted to your Account as of the next business day. If you have misplaced your envelope send, your payment to Discover Bank, PO Box 6103, Carol Stream, IL 60197-6103. Please allow 7-10 days for delivery. If your payment is returned unpaid, 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 sufficient funds are available in your bank account, and 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 from your bank account, and to initiate debit or credit entries to your bank account, as applicable 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 as the Minimum Payment Due or the New Balance on each statement You can cancel a paygent however we must receive notice at least three business days in advance of the scheduled payment. You may notify us by phone at 1-800-347 3683 or by mail at address listed in the previous paragraph. 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 monthry statement based on credits or payments applied during the billing cycle. Credit Reporting. We may report information about your account to credit bureaus Late payments, missed payments, or other defaults on ^'our account may be reflected in your credit report We normally report the status and payment history of your Account to credit reporting agencies §ach month. If you believe that our report is inaccurate or incomplete please write us at the following address: Discover 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 Balance, by making payments or receiving credits. However, if you paid the New Balance on your previous billing statement by thhe 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 grace period. Otherwise, you will receive a billing statement next month that includes Periodic appearing 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 purchases subject to a standard rate would be separate groups. We refer to these groups as transaction categories. At the end of each billing period, we compute balances and Periodic Finance Charges for each day of the billing period for each transaction category. We use the followinDg equation to compute Periodic Finance Charges for each transaction category Average Daily Balance x number of days in the billing period xairy Periodic Rate. (You may refer to the finance charge summary on your billing statement for these amounts.) Then we add up the-Periodic Finance Charges for each transaction category to get the total Periodic Finance Charges for your Account The Average Daily 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 daily average balance (including new transactions method of calculating the balanceV upon which we impose Periodic Finance Charges. This means if you did not pay the New Balance shown on he billing statement you received during the previous billing period by the Payment Due Date shown on that statement we will impose Periodic Finance Charges on new purchases that first appeared on that billing statement as well as new purchases that first appear on the current tilling statement unless we already imposed Periodic Finance Charges on the purchases on your previous billing statement We compute the Average Dairy Balance for each transaction category by adding up all the dairy balances in a billing period for a transaction category and dividing the total by the number of days in the billing cycle. a compute the daily balance for each transaction cateoory on each day by-12 adding the following to the previous day s daiN balance: transactions made that day, fees charged 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 daffy balance for the first day of the. billing period, we consider the previous day's 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 hawng 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 category with the exception of Finance Charges which are added to the applicable cash advance transaction category and Balance Transfer Transai are added to the applicable balance transfer transaction category. When a special balance transfer rate expires, we balance transfer and the Balance Transfer Transaction Fee Finance Charges to the standard purchase transaction c rate has been terminated under the Default Rate Plan, we leave the unpaid balance of the balance transfer and the I Finance Charges in the applicable transaction category until the special rate would have expired. For TOO (Telecommunications Device for the Oeaf) assistance, please call 1-1100-917.71aa VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unworn. falsifications to authorities, that she is Jennifer Noble (Name) Accounts Manager of DFS Services LLC , plaintiff herein, that (Title) (Company) 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 her knowledge, information and belief. (Signa ) WWR# 7353546 Theresa L. Todd '6011002010669737 G F,I cl., T,p f ??4f'?? 24 >,"111 -09.60 PO A7W 0,1(-* 4004 RM P--M` aa4a19 Sheriffs Office of Cumberland County R Thomas Kline r et'CU146 Edward L Schorpp Sheri Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFCE C P THE $?- RIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/27/2009 09:13 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on April 27, 2009 at 2113 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Theresa L. Todd by making known unto Teresa L. Todd personally, at 803 W. Keller Street, Mechanicsburg, Cumberland County, Pennsylvania, 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $36.10 SO ANSWERS, April 28, 2009 R Y Docket No. 2009-2579 Discover Bank v Theresa Todd SHERIFF C'7 ?v -' C4 ;?fr C" U 1? DISCOVER BANK Plaintiff VS. THERESA L TODD Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION No: 2009-2579 PRAECIPE FOR DEFAULT JUDGMENT 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 07353546 C A Pit JLI Judgment Amount $12038.54 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. THERESA L TODD TO THE PROTHONTARY: Civil Action No. 2009-2579 PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant THERESA L TODD above named, in the default of an Answer, in the amount of $12038.54 computed as follows: Amount claimed in Complaint $10538.54 Less payments / adjustments made $0.00 Attorney's fees $1500.00 TOTAL $12038.54 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: James C. 0735354 Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P. Pittsburgh, PA 15219 And that the last 803 W KELLER ST MECHANICSBURG, PA 1705 A Pit JLI 6 Seventh Avenue, Suite 1400 address of the Defendant is: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 2009-2579 THERESA L TODD 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 is the affiant's belief that the Defendant , THERESA L TODD 803 W KELLER ST MECHANICSBURG, PA 17055 is not in military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMSC), which states that the Defendant , THERESA L TODD 803 W KELLER ST MECHANICSBURG, PA 17055 is not in the military service. Further Affiant sayeth naught. SWORN TO AND SU%SCgIBED in my presence this ?l day of/ jV n e- zj"9 COMMONWEALTH OF PENNSYLVANIA_ Notarial Seal Wayne A. Jones, Notary PuNic City of Pittsburgh, Allegheny County Commission Mires June 28, 2010 MMRI F, PORMWWO n of NW*deaj IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. THERESA L TODD Defendant Case No. 2009-2579 IMPORTANT NOTICE TO: THERESA L TODD 803 W KELLER ST MECHANICSBURG, PA 17055 Date of Notice: 510VNlbq 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 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA. 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A. By. .- Matthe y P.A.I.DX 90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 7353546 A PIT B4B Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 JUN-02-2009 06:34:46 Last Name First/Middle Begin Date Active Duty Status Service/Agency TODD THERESA 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. 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: hitp://www.defenselink.mil/fN/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 /D:I0NCQNPL4Z https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 6/2/2009 OF THck `'f,f`?fiRY 2009 JUN 15 PH 1: 19 PEM: YLV INI', pa, m ?? Nok??7ti IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. THERESA L TODD Civil Action No. 2009-2579 NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order of Judgment was entered against you on WWI (xx) Assumpsit Judgment in the amount of $12038.54 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 THERESA L TODD 803 W KELLER ST MECHANICSBURG, PA 17055 Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-2579 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s) From THERESA L. TODD, 803 West Keller Street, Mechanicsburg, PA 17055 (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: CITIZENS BANK, 665 NORTH EAST STREET, CARLISLE, PA 17013 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 $12,038.54 Interest $1,618.55 Atty's Comm Atty Paid $155.60 Plaintiff Paid Date: 9/28/11 (Seal) REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUQIRE L.L.$.50 Due Prothy $2.00 Other Costs David D. Buell, Prothonotary Deputy Address: WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 KOPPERS BUILDING, 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 47437 IN THE COURT OF COMMON PLEAS OF CUMBERLANI? COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. THERESA L TODD ?3 w teller s? . Defendant(s) Civil Action No. 2009-2579 %-e&.pv\ nueos CITIZENS BANK ?? sfT?? C?•t?? t l-a?`?S?C ??? Garnishee(s. PRAECIPE FOR WRIT OF EXECUTION TO TfIF PROTHONOTARY: Kindly issue:. a Writ of Execution in the above matter... i . directed to the Sheriff of CUMBERLAND County: 2. against THERESA L TODD , Defendant 3. against CITIZENS BANK... Garnishee 4 Judgment Amount Less Payments/credits received Interest Cos-is SU1'il'O FAL: Co,.,!,, (to b,-, added by Prothonotary): 614 DIA a 3?.1o CgF 14.00 It It g S. 46 a-, r &. Vt.. 4,0 LL. ev'W101-as10q P-w a1V1;'93(P co CD - v C rV a $ $12,038.54 $ $0.00 $ $1,618.55 $13,657.09 WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. Molczan. Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO.. L.P.A. 1400 Koppers blilding 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 7353546 ?Ut + q & T's ue'l IN THE i::OURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 2009-2579 VS. PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) "i HERESA L TODD Defendant(s) C] I'ZENS BANK Gar-i ishee(s) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. 447437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 7353546 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor H ! 1 OC -4 Per ti" BEffl A[I CC?UN' ` 'Eh314SY[AfAN f?; Discover Bank vs. Theresa L. Todd Case Number 2009-2579 SHERIFF'S RETURN OF SERVICE 09/30/2011 10:35 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, Citizens Bank at 665 North East Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to JANINE SHEAFFER, TELLER MRG, personally 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 October 3, 2011 to Theresa L. Todd at 803 W. Keller Street, Mechanicsburg, PA 17055. SHERIFF COST: $300.27 October 03, 2011 SO ANSWERS, RON ANDERSON, SHERIFF iam Cline, Deputy ?:nirr ort? fie' TP :>,ft. h-, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION DISCOVER BANK Plaintiff(s), VS. THERESA L TODD Defendant(s), and Citizens Bank of Pennsylvania, Garnishee r:T Cfl ? _ _LL, ?-. > C') d;y L ) .?-.. . - 09-2579 ' - - ANSWERS TO INTERROGATORIES OF GARNISHEE, CITIZENS BANK The Garnishee, Citizens Bank of Pennsylvania responds as follows to the Interrogatories of the Plaintiff(s): (NUMBERS _l_ to _12-) At the time of service of above-captioned Writ of Execution and to the present, Citizens Bank of Pennsylvania provides the following Answers to Interrogatories: The Garnishee, Citizens Bank of PA, states that it maintains a joint checking and savings account in the name of the Defendant, THERESA L TODD, with a balance less than the $125.00 Garnishee's processing fee. Therefore, no funds are available subject to this Writ of Execution. COMMONWEALTH OF PENNSYLVANIA SS: COUNTY OF ALLEGHENY Before me, the undersigned authority, a Notary Public in and for said Commonwealth and County, personally appeared Kasie Crowley who being duly sworn according to the law deposes and says that she is the Legal Clerk, Operations Services, and that the statements set forth in foregoing Answers to Interrogatories are true and correct to the best of her knowledge, information, and belief ka:ie ey Sworn and subscribed before me this 200' day of October, 2011. ONO Notary Public of p%NSyLVA141A G 1M Ses? PUW d'M"y County Cty Of 236 2014 MY Asso?adw of Notaries Member, Penns V Certificate of Service I, Kasie Crowley, hereby certify that a true and correct copy of the Answers to Interrogatories has been served upon the following by depositing it in the U. S. Mail, postage prepaid, this 20th day of October, 2011. WILLIAM T MOLCZAN, ESQ WELTMAN, WEINBERG & REIS CO, LPA 1400 KOPPERS BLDG PITTSBURGH, PA 15219 -?7 Kasie tmwlor IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PA CIVIL DIVISION DISCOVER BANK, Plaintiff(s), VS. THERESA L TODD, Defendant(s), VS. Citizens Bank of Pennsylvania, Garnishee 09-2579 Answers to Interrogatories Code: 200 Execution Filed on Behalf of Garnishee, Citizens Bank of Pennsylvania Counsel of Record for this Party: Nicholas Deenis, Esquire PA I.D. No. 62378 Stradley, Ronon, Stevens & Young Great Valley Corporate Center 30 Valley Stream Parkway Malvern, PA 19355-1481 (484) 323-1351 (610) 640-1965 fax ndeenis@stradley.com www.stradley.com WELTMAN, WEINBERG & REIS CO., L.P.A. BY: Sarah E. Ehasz, Esquire Attorney for Plaintiff(s) I.D. No.86469 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 7353546 DISCOVER BANK Plaintiff # - 0i MUEB 27 AN 11: 03 CUMBERLAND COUNTY PENNSYLVANIA CUMBERLAND County Court of Common Pleas vs. THERESA L TODD Defendant(s) NO. 2009-2579 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. By Before me the ?Z-day, f-aw , 2012 Notarial $E ;? R f as E plr !r- ?. 2014 Sarah E. Ehasz, Esquire Attorney for Plaintiff G1 I So WELTMAN, WEINBERG & REIS CO., L.P.A. Sworn to and subscribed