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Home My WebLink About09-2634 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK P l a int i f f No : (? - 1(,3q eA.; lem vs. SEMOY T SMITH 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 07353760 C A Pit ABR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No SEMOY T SMITH 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 s 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: SEMOY T SMITH 1256 ALMA LN MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXX5481 . 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 16, 2009 , in the amount of $4846.78 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 $500.00 . 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 , SEMOY T SMITH INDIVIDUALLY , in the amount of $4846.78 with interest at the legal rate of 6.00001 per annum from date of judgment plus attorneys' fees of $500.00 , and costs. WELTMAN INBERG & REIS CO., L.P.A. 436 Sev nt Avenue, Suite 1400 Pittsb rg PA 15219 (412) 34 7955 FAX: 12 38-7130 07353 6 C A Pit ABR This law firm is a debt collector attempg to collect this debt for our client and any information obtained Will be used for that purpose. -- 1 w r. ` J4,040.10 ,-A RD 22 SDSN6A01 0004633 SEMOY SMITH 1256 ALMA LN MECHANICSBURG PA 17055-9710 54,846.78 Enter Amount Enclosed Below Payment Due Date $ -7 :;4 47- , --j ?Q March 21, 2009 please make check payable to Discover Card. Minimum payment due includes a past due amount of $1,087.00. Will your payment get to us on time? Pay your bill online and your payment can be made to your account on the same day. Visit Discover.com/payments today. PO BOX 6103 11LrriIN to nif II11.lrllul CAROL STREAM IL 60197-6103 l,111111,nnilll1lnlr,11111,1111l1111111111111111111111111ll 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. 000001986458846909089048467800000000484678 Discover More Card Account Summary Closing Date: February 22, 2009 Account number ending in 5481 Payment Due Date March 21, 2009 Minimum Payment Due $4,846.78 Credit Limit $12,100.00 Credit Available $0.00 Cash Credit Limit $0.00 Cash Credit Available $0.00 page 1 of 1 Previous Balance $4 846 78 6 Payments And Credits , . Purchases .00 Cash Advances + 0.00 Balance Transfers + 0.00 Finance Charges + 0.00 _ New Balance - + ------_ --? $4,846.78 Cashback Bonus® O i pen ng Cashback Bonus Balance $ 0.00 New Cashback Bonus Earned + 0 00 Cashback $oms® Anniversa ry - Cashback Bonus Balance $ 0.00 Available lo Redeen> i Date: February 22 _ . _ _ . _ ....._ -.0.00- $ How Can We Help You? 1. Visit Discover.com to pay your bdl for no c t i It's your choice - 3 ways to help os , v ew your latest Account information, earn and redeem rewards and more 2. Call 1-800-DISCOVER (347.2683) F f Please have your Discover Card available. For TDD (assistance for hearing impaired) see reverse side or ast, easy self service options or to speak with a Customer Service Account Manager 3' Write us at Discover Card, PO Box 30943 , Salt Lake City, UT 84130 Finance Charge Summary Averse g e Dail y R Nominal ANNUAL NTAGE ANNUAL NTAGE Periodic Transaction Fee Balances current billing period: 31 days atess RATES RATES FINANCE CHARGES FINANCE CHARGES Purchases $0 Cash Advances $0 0.07942% 28.99% F 28.99% $0 Balance Transfers $0 0.07942% 0 07942% 28.99% F 28.99% $0 none $0 previous billing period: 22 days . 28.99% F 28.9990 $0 $0 Purchases $0 0.07942% 28.99% F 28.99%, $0 The rates that aPPIY to your Account are either fixed (F) or the none y may vary (V) as n oted above. EXHIBIT -?-- L 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 Lost or stolen cards. Report immediately! Call 1-800-347-2683. B68ng Rlpluts Summer y. In Case of Errors or Ouestions About Your Bill: If you think your bill is wrong, or if yyoou need more information aboutlea transaction on your bill, write to us on a separate sheet of paper at Discover Card; PO Box 30421, Salt Lake City, U7 84130.0421, as soon as possib. 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 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. .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 investigate your question, we cannot report you as delinquent or take any action to collect the amount you question. Speeral Rule for Credit Card Purchases: If you have a problem with the quality of gods or services that you have tried in good faith to correct the problem with the merchant, you may not have to pay the remain,npcanieouM due on thecggao as or services. You have this protection only when the purchase price was. more than $5y0 and the purchase was made in your home state or wthin 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.) end desc ibed avo Send, you authorizeyusoto use information on your check ommake atn electronicefund rransferrffromtysour account8at thedfrinancial 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 yo ur check to make an electronic fund transfer, funds may be w6drawn from your account as son 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 address or if you use ari envelope other than.-the c+ne provi&c'_ .Payments received-on. or. payment, if y p Friday- the payment to any or bank holiday will be posted to your Account as of the next business day. If you have misplaced yourf envelope alend your paym nt to Di cover Bank, PO Box 6103, Carol Stream, rL 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 lrour bank account information. Ypu must ensure that sufficient funds are available in your bank account, and all trumbersons 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 from your electronic signature, u will be agreeing to this authorization to allow us and your bank to deduct each a ent your bank account, and to initiatedebit or credit entries to yo p ym you authorize payment You must tell us the amount of each a ment, or your bank account, such applicable, to correct an error the processing of such each statement You can cancel warent, howevyer we must receivvesnoticeaat leasst thrusiness da s in a Payment Due the New Balance o may notify us by phone at 1-800.347 3683 or by mail at address listed in the previous Paragraph. If yourmpayments of lhvary scheduled payment. You u indicated onhthe monthly statementhbased on credits o payments applied doing the billing Cycle Your Automatic y r yin amount we will tell payment amount may be lass than Credit Reporting, We may report information about your account to credit bureaus. Late a yms account may be reflected in your credit report We normally report the status and payyment history oflyour? AC ount locredit rrepother lts on ortind. agenc es to h month. If you believe that our report is inaccurate or incomplete please write us at tfie following address: Discover Card, PO Box 1516, 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 pa your entire New Balance, by Making payments or receiving credits. However, if billing statement by the Payment Due Date shown on that statement, and g you paid the New Balance your your previous statement, we will not impose Periodic Finance Charges on new purchases, that is, the purchases Ifirst a?p the Payment Due Date on your current billing the grace period. Otherwise, you will receive a billing statement next month that includes Periodic FinancegCharges on those new purchases. call Thtere is no grace period on balance transfers or cash advances. their Annualr Percentages Rate. gForP example, purrchases subject to an promotionalr rate ands purchasesrt subject tthe atstandard 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 followmp equation to compute Periodic Finance Charges for each transaction category, Average Daily, Balance x number of days in the billing period x Daily Periodic Rate (You may refer to the finance charge summary on your biling statement r these amounts.) Then we add up the Periodic Finance Charges for leach 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 balance upon which we impose Periodic Finance Charges. This means if you did not pay the New Balance shown on the billing statement you received durin® the previous billing period by the asywell as newaturcha es that firsttappearnon thwill rrent billingstatementcunless?we already imposed Periodtic F nanceaCharges ontthe purchaseseon your previous billing statement We compute the Average Dairy Balance for each transaction category by adding up all the daily balances in a billing period for a transaction category adding ?theToll wing total theepreviousrday's dailyy balance ling transactioons made that hday daily feeschargedrtihat day and Periodic Finance Chargesyacc ued on the previous day's daily balance; and b then subtracting any credits and payments that are applied against the balance of the transaction yategory on that day. In calculating the laity balance for the first day of the billing period, we consider the ' previous day's balance" to have been our bballance 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 category with the exception of Cash Advance Transaction Fee Finance Chargges which are added to the applicable cash advance transaction category and Balance Transfer Transaction Fee Finance Charges which are added to the applicable balance transfer transaction category. When a special balance transfer rate expires, we move the unpaid balance of the rate has transfer rminated under therDefault Transaction twe leaveathe unpaid balance osf the balancehtransferyandithe Balance Transfer TiansactiooneFee cial Finance Charges in the applicable transaction category until the special rate would have expired. For TOO (Telecommunications Device for the. n..n ...1.#.- .1 ..._ -- . ..-. - - Cn 0 co z m 0 o° C4 CJ N 0 v VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unswom 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. (Si (ae) WWR# 7353760 Semoy T. Smith '6011002750745481 0 I'0 :?t'„lti28 C, EtiI i V "l3 x'18.50 PD ATN e* 4009 l c s PTt 12.eg306 Sheriffs Office of Cumberland County R Thomas Kline v,tp of C11416r? Edward L Schorpp Sheriff LOM Solicitor Ronny R Anderson Jody S Smith Chief Deputy "'F 'HE S"ER"F Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/30/2009 03:15 PM - Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on April 30, 2009 at 1515 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Semoy T. Smith, by making known unto herself personally, defendant at 1256 Alma Lane Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handinc to her personally the said true and correct copy of the same. SHERIFF COST: $34.30 SO ANSWERS, May 04, 2009 R THOMAS KLINE, SHERIFF 2009-2634 B/? L? Y Discover Bank Deputy Sheriff VS Semoy T. Smith A - ? 3 - ?..'; --c r rr?- 73 co r n •- C t DISCOVER BANK Plaintiff VS. SEMOY T SMITH Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION No: 09-2634 CIVIL TERM 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 07353760 C A Pit JLI Judgment Amount $5346.78 w IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 09-2634 CIVIL TERM SEMOY T SMITH PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONTARY: Kindly enter Judgment against the Defendant SEMOY T SMITH above named, in the default of an Answer, in the amount of $5346.78 computed as follows: Amount claimed in Complaint $4846.78 Less payments / adjustments made $0.00 Attorney's fees $500.00 TOTAL $5346.78 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. 0735376 Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A Pittsburgh, PA 15219 And that the last 1256 ALMA LN MECHANICSBURG, PA 17055 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. 09-2634 CIVIL TERM SEMOY T SMITH 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 , SEMOY T SMITH 1256 ALMA LN 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 , SEMOY T SMITH 1256 ALMA LN MECHANICSBURG, PA 17055 is not in the military service. Further Affiant sayeth naught. SWORN TO AND SUE5CgIBED in my presence this day of Z0019 . COMMONW EA O?F PENNSYLVANIA Heidi J. Kelly, Notary Public Allegh?Y County City Of P'dtsbur5 tes Nov. 4, 209 MY COMM .. n Member, PennsYlvania Assoclatlon of Notaries IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. SEMOY T SMITH Defendant TO: SEMOY T SMITH 1256 ALMA LN MECHANICSBURG, PA 17055 Date of Notice: _7- Case No. 09-2634 CIVIL TERM IMPORTANT NOTICE 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,4NEINBERG & REIS CO., L.P.A. Ma ew Urban ""- P.A.I.DA 90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, 140D Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 7353760 A PIT 13413 RB)-i?`'NCE OF THE MI THNOTARY 2009 JUN 29 PM 2: 3 3 CUM :%? :a wwl-I •i1 PENNSYLVANIA *14.00 po AT l M, lqoq logo 04 l IJokcA. ?? y IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. SEMOY T SMITH Civil Action No. 09-2634 CIVIL TERM 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 q/011 (xx) Assumpsit Judgment in the amount of $5346.78 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 Pro SEMOY T SMITH 1256 ALMA LN MECHANICSBURG, By: 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 09-2634 Civil CIVIL ACTION -- LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From SEMOY T. SMITH, 1256 Alma Lane, Mechancisburg, 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: MEMBERS IT FCU, 1711 Spring Road, 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 $5,346.78 Interest -- $879.37 Atty's Comm % Atty Paid $158.30 Plaintiff Paid Date: 4/y/12 (Seal) L.L.$.50 Due Prothy $2.25 Other Costs --?aA'4•2 1. David D. Buell, Prothonotary c Deputy REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO, LPA 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 47437 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 09-2634 CIVIL TERM vs. PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) SEMOY T SMITH Defendant(s) MEMBERS I ST FCU M cj- r'7 M; Garnishee(s) - FILED ON BEHALF OF `- _ Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 7353760 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 09-2634 CIVIL TERM SEMOY T SMITH , /a5(o Afrna. Ln, Me k, PA lr)o,,j5 Defendant(s) MEMBERS IST FCU, 1711 aprin9 (J, 0-&fi1iSle, PA 170/3 Garnishee(s) PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: 2. against SEMOY T SMITH , Defendant 3. against MEMBERS 1 ST FCU,, , Garnishee 4. Judgment Amount Less Payments/credits received Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): O #a4. oo Po A-MV 3y.30 Car 78. so 14-oo 150 " f158. so -Pb AI" 4o1.o2s DU4 .50 LL.. 01044$ 4N 7 e a*73500 Lori+Js&w d rn $ $5,346.78 $ $0.00 $ $879.37 $6,226.15 w 3.- WELTMAN, WEINBERG & REIS CO., L.P.A. 4 4 ??' , By: William T. Molczan, ire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 7353760 `- CD SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Discover Bank vs. Semoy T. Smith ?^ 5 y iaaub`?? t{?rt??? ?a._ tit n Case Number 2009-2634 SHERIFF'S RETURN OF SERVICE 04/13/2012 09:55 AM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on April 13, 2012 at 0940 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Semoy T. Smith, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union at 1711 Spring Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Melinda Wilkins, Member Services Representative, 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 April 17, 201 Ito Semoy T. Smith at 1256 Alma Lane, Mechanicsburg, PA 17055. SO ANSWERS,, April 16, 2012 RON R ANDERSON, SHERIFF William ine, Deputy GounyS.aitfl S^enff_ Tei?oS.>"t. let. WELTMAN, WEINBERG & REIS CO., L.P.A. BY: Matthew D. Urban, Esquire I.D. No.90963 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 7353760 t tJ?- r ?C'L Attorney for Plaintiff(s) :. N Pill 2: J t'P of ?A UU 71: A DISCOVER BANK vs. SEMOY T SMITH, and MEMBERS 1 ST FCU Garnishee(s) CUMBERLAND County Court of Common Pleas NO. 09-2634 CIVIL TERM PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the above matter discontinued and ended as to Garnishee(s), MEMBERS 1 ST FCU,, only. WELTMAN, WEINBERG & REIS CO., L.P.A. C By Matthew D. Urban, Esquire Attorney for Plaintiff I hereby certify that the foregoing is a true and correct statement of the above case. This statement is made subject to the penalties of 18 Pa.C.S. 4904 relating to unsworn falsifications to authorities. 9.5UI34 007 p# a?UU3$ WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-2634 Civil CIVIL ACTION -LAW ~f0 TH} SI{ERIFP OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due D[SCOVER BANK, Plaintiff (s) From SEMOY T. SMITH, 1256 Alma Lane, Mechancisburg, PA 17055 r I) Yon are directed to levy upon the property of the defendant (s)and to sell t?) Yozi are also directed to attach the property of the defendant(s) not levied upon in the possession o t' C~ARNIS1~iEE(S) as follows: MEMBERS iSZ FCU, 1711 Spring Road, Carlisle, PA 1'.7013 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, (~) 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 ~}arnishec and is enjoined as above stated. Arninznt Due $5,346.78 Lzterest -- 5879.3 Atty's Cz~mm °% Atzv Paid 5158.30 Plaintiff Paid Date: 4/9i 12 (Seal) RI:QUEST•11~'G PARTY: L.L.5.50 Due Frothy $2.25 Other Costs ~.~~~.~o _ ____________ avz D. Buell, Prothonotary Deputy ~- Nami WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO, LPA 1400 KOPPER5 BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA ] 5219 Attorney for: PLAINTIFF 7~e lephone: 412-434-7955 Supreme Court ID No. 47437 TRUE COPY FF"'~ "~ RECORD In Testimony wnereot. ~ ~ , iio set my hand and the seal of paid Cour~ r s: ~.~-ariisle, Pa. This ~ day Of ~ 1 ( . 20 L-_ ~~~~ Prothonotary SHERIFF'S OFFICE OF CUMBERLAND COUNTY konny R Anderson Sheriff _ > , ,- .__ ~, r; ;,c~i~ii ~ Jr Jody S Smith ~ ~ ` ;`x, ~ ~ ~ ~ } Chief Deputy ~„;~~~~~~ _~ ~~~ ~~: C ty Richard WStewart - - - Soiicitor ~'!~~'~~~~~, , r, `~r~J C~ J r ~ ~ . rA t rr Discover Bank -' vs. Case Number Semoy T. Smith 2009-2634 SHERIFF'S RETURN OF SERVICE 04/13/2012 09:55 A~/I -William Cline, Deputy Sheriff, who being duly sworn according to law, states that on April 13, 2012 at 0940 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Semoy T. Smith, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union at 1711 Spring Road, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Melinda Wilkins, Member Services Representative, 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 April 17, 2011 to Semoy T Smith at 1256 Alma Lane, Mechanicsburg, PA 170'i5. 11/07/2012 Ronny R Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $87.x12 SO ANSWERS, ~ , November 07, 2012 RON R ANDERSON. SHERIFF ~~ ~~ ~~~~