Loading...
HomeMy WebLinkAbout09-7790 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: aq_ 7790 aivil lety vs. COMPLAINT IN CIVIL ACTION KELLY GREER 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 07718782 C A Pit KMJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No KELLY GREER Defendant COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff, DISCOVER BANK is a corporation with offices at 6500 NEW ALBANY ROAD NEW ALBANY , OH 43054 . 2. Defendant is adult individual(s) residing at the address listed below: KELLY GREER 9 OAK AVE ENOLA, PA 17025 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX1001 . 4. Defendant made use of said credit card and has a current balance due of $8697.91 , as of August 11, 2009 . 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 28.990. per annum on the unpaid balance from August 11, 2009 . A copy of Plaintiff's Statement is attached hereto, marked as Exhibit I'll' and made a part hereof. 7. Plaintiff avers that the Agreement between the parties provides that Defendant will pay Plaintiff's attorneys' fees. 8. Plaintiff avers that such attorneys' fees will amount to $125.00 . 9. 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 , KELLY GREER individually , in the amount of $8697.91 with interest at the rate of 28.990% per annum from August 11, 2009 plus attorneys' fees of $125.00 , and costs. WELTMINBERG & REIS CO., L.P.A. fames )2ChA rmbrodt,42524 436 SAvenue, Suite 1400 PittsPA 15219 (412) 955 FAX: 8-7130 0771 Pit KMJ 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. Ulbkr ".._ V hK S0.00 $1,780.00 Enter Amount EnclOsad Below CARD --- ---- J Payment Due Date $ L i? August 26, 2009 31 SDSWA01 0004726 KELLY GREER 9 OAK AVE ENOLA PA 17025-1018 Address, e-mail or telephone change? Print change in space above, or go to Discovencom. Print your e-mail address to receive important Account information and special offers. 000001986618094652307000000000000000178000 Discover More Card Account Summary Closing Date: July 31, 2009 page 1 of 1 Account number ending in 1001 Previous Balance $8,697.91 Payment Due Date August 26, 2009 Payments And Credits 8,697.91 Minimum Payment Due $1,780.00 Purchases + 0.00 Credit Limit $7,100.00 Cash Advances + 0.00 Credit Available $0.00 Balance Transfers + 0.00 Cash Credit Limit $2,000.00 Finance Charges + 0.00 Cash Credit Available $0.00 New Balance z $0.00 Cashback Bonus® Opening Cashback Bonus Balance $ 0.00 New Cashback Bonus This Period + 0.00 Cashback Bonus Balance $ 0.00 Cashback Bonus® Anniversary Date: September 9 How Can We Hel YOU? 1 • Visit Discover.com 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 8,4130 Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence. Trans. Post Date Date Payments and Credits Jul 31 Jul 31 INTERNAL CHARGE-OFF $ -8,697.91 h 1 Finance Charge Summary Average Daily Nominal ANNUAL ANNUAL Periodic Transaction Fee Daily Balance s Periodic Rates PERCENTAGE RATES PERCENTAGE RATES FINANCE FINANCE CHARGES CHARGES current billing period: 22 days Purchases $0 0.07942% 28.99% F 28.99% $0 $0 Past Purchases $0 0.07942% 28.99% F 28.99% $0 $0 Cash Advances $0 0.07942% 28.99% F 28.99% $0 $0 0 !Cu ?? D 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 Illn?lluu?llnullrllul CAROL STREAM IL 60197-6103 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 cn Z V Lost or stolen card:. Report immediately! Call 1-886-34T-2683. Z m D 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 o 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. N 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 if you use an envelope other than the one provided. Payments received on or after 1 PM at our processing facility Mondayy through Friday or on a weekend or bank holiday will be posted to your Account as of the next business day. If you have misplaced your emrolope, 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 ur minimum payment or a greater amount over the telephone, and you can set up automatic payments. Call us at 1.888-347-2683. You will needythis statement and your bank account information. You must ensure that sufficient funds are available in your bank account and all transactions must comply with US law. You will be asked to provide the first 5 digits of your account statement zip code. By entering these 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 payments. 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 payment; however, we must receive notice at least three business days in advance of the scheduled payment You may notify us by phone at 1-888.347-2883 or by mail at the 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 less than indicated on the monthly 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 your account may be reflected in your credit report If you believe that our report is inaccurate or incomplete, please write us at the following address: Discover Business Card, PO Box 15316, Wilmington, DE 19850-5316. Please include your name, address, home telephone number and Account number. Periodic Finance Charges. We begin to impose Periodic Finance Charges on all transactions from the Transaction Date for the transaction as shown on your billing statement, unless a transaction is posted to your Account after the close of the billing period in which it occurs, in which case we begin to impose Periodic Finance Charges on that transaction from the first day of the billing period in which it is posted to your Account. We continue to impose Periodic Finance Charges 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 the Payment Due Date shown on that billing 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 apppeeaaring on the current billing statement We call this the "grace period." There is no grace period on balance transfers, cash advances, or PurchaseChecks. We sort your transactions into grou s 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 following equation to compute Periodic Finance Charges for each transaction category. (Average Daily Balance) times (days in billing period) times (Daily Periodic Rate). (You may refer to the finance charge summa7,n on your billing statement for these amounts.) Then we add up the Periodic Finance Charges for each transaction category to get the total Periodic ane 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 Average Daily Balance (including new transactions) method of calculating the balance upon which we impose Periodic Finance Charges. We compute the Average Dally Balance for each transaction category by adding up all the daily balances in a billing period for a transaction category and dividing the total by the number of days in the billing period. We compute the dally balance for each transaction category on each day by first adding the following to the previous days dally balance: transactions with a Transaction Date of that day as shown on your billingg statement, unless the transaction is posted to your Account after the close of the billing period in which it occurs, in which case the transaction wilr be added to the daily balance as of the first day of the billing period in which it is posted to your Account, fees charged that day and Periodic Finance Charges accrued on the previous days 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 billing period, we consider the "previous day's daily balance" to have been your balance for each transaction category on the last day of your previous billing period. All fees charged to your Account are added to the standard purchase transaction category with the exception of Cash Advance Transaction Fee Finance Charges which are added to the applicable cash advance transaction category and Balance Transfer Transaction Fee Finance Charges which are added to the applicable balance transfer transaction category. When the special rate expires, we move the unpaid balance of the balance transfer and the Balance Transfer Transaction Fee Finance Charges to the standard card purchase transaction category. However, if the special rate has been terminated under the Default Rate section, we leave the unpaid balance of the balance transfer and the Balance Transfer Transaction Fee Finance Charges in the applicable balance transfer transaction category until the special rate would have expired. For TOO (Telecommunications Device for the Deaf) assistance, please call 1-800-347-7448. The Discover Business Card is issued by Discover Bank, Member FDIC. VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsifications to authorities, that he is. .. Aaron Spain (Name) Accounts Manager of DFS Services LLC , plaintiff herein, that (Title) (Company) he 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 knowledge, information and belief. Signat e) WWR# 7718782 Kelly Greer '6011298651601001 0 1 1'"{ u L f * is. 50 Po A- Try Cr.'s ?.3otcd4l a33o2(p SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant e p,,,? OF THE NOTARY Edward L Schorpp Solicitor Discover Bank vs. Kelly Greer 2009 NOW 19 PM 12: 5 7 CUMbE t } " 6 ' OJNTY PEWS'oUAN A Case Number 2009-7790 SHERIFF'S RETURN OF SERVICE 11/16/2009 05:20 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on November 16, 2009 at 1720 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Kelly Greer, by making known unto herself personally, at 9 Oak Avenue Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.50 November 17, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF Depu y Sheriff te; CountySuite Shenff, Teleosoft. Inc. 1 ~ ~-, i ,~`.tl~ cu~~~~ :4 ,~,;1~NTY IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DNISION DISCOVER BANK Plaintiff vs. KELLY GREER Defendant No. 09-7790 CIVILTERM PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) AMERICHOICE FEDERAL CREDIT UNION, Garnishee, 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#07718782 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CNIL DNISION DISCOVER BANK Plaintiff vs. Civil Action No. 09-7790 CNILTERM KELLY GREER , q Oal~. Rve ~ E,tto~a PA (~ pa5 Defendant AMERICHOICE FEDERAL CREDIT UNION, Z15 WertzU~Ite`~d, ~na~z PA Ilo~ Garnishee TO THE PROTHONOTARY: PRAECII'E FOR WRIT OF EXECUTION Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: 2. against KELLY GREER, Defendant 3. against AMERICHOICE FEDERAL CREDIT UNION, Garnishee 4. Judgment Amount $ 9,465.38 Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): ~J ~a1~.50 P(~ A'N'N x{1.50 cF3F 78.50 ~~ 1~. oo ~~ a.so ~, ~ !(vl . 00 - Po ArN ~a.oo due. Co • 50 ll. $ 172.71 $ 9,638.09 WELTMA~YWEII~fBERG & REIS CO., L.P.A. B~ v 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 e~ a~a~s9 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-7790 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From KELLY GREER, 9 Oak Avenue, Enola, PA 17025 (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: AMERICHOICE FEDERAL CREDIT UNION, 715 Wertzville Rd, Enola, PA 17025 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 $9,465.38 Interest L.L. $.50 Atty's Comm Atty Paid $172.71 Plaintiff Paid Date: 5/26/10 (Seal) REQUESTING PARTY: Name MATTHEW D. URBAN, ESQUIRE Due Prothy $2.00 Other Costs Da id D. Buell, Prothonotary Deputy Address: WELTMAN, WEINBERG & REIS CO., LPA 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 90963 WELTMAN, WEINBERG & REIS CO., L.P.A. BY: Matthew D. Urban, Esquire I.D. No.90963 436 Seventh Avenue, Suite 1400 Pit#sburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 07718782 DISCOVER BANK vs. KELLY GREER and AMERICHOICE FEDERAL CREDIT UNION Garnishee(s) Attorney for Plaintiff(s) ~ '~ CUMBERLAND County . R V~ nI ' Court of Common Pleas ~-~ ~ C .-- kr , ~ Z NO. 49-7790 CIVILTERM ~'= - rv ~ '~'" :r:.,~ ~_~_. -; ; ~,; ; ~~ . ~l t~ - h ';, ` r~; ~.: --t PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter settled, discontinued, and ended, as to Garnishee(s), AMERICHOICE FEDERAL CREDIT UNION, only. WELTMAN, INBERG 8~ REIS CO., L.P.A. Y _ Matthew D. Urban, Esquire Attorney for Plaintiff Sworn to and subscribed Before me t$e Z~- Day of JUNE, 2010 NOTARY PUBLIC ~ COMMONWEAL-TH OF PENNSYLVANIA Notarial Seal Public Sheila G. i3ovan, Notary City Ot f i;1~5ur9h, Allegheny CGUniy N;y Commission F_xpires Nov. 15, 2010 ~~~ ,.,an~N p•~~tl" ",+,n of Nataries MBmr,ni, ~'d~"'y ~P;00~~ ~~ ~-~I3S~ SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff FILED-OFFICE ??u1v at ?t,r?trr l,? THE ?-O HOD .k +ar Jody S Smith Chief Deputy JAN-6 AM 9: 29 Richard W Stewart SolicitorF; F1MFLtJ+3 'j` PENNS Discover Bank Case Number vs. Kelly S. Greer 2009-7790 SHERIFF'S RETURN OF SERVICE 06/14/2010 04:35 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on June 14, 2010 at 1635 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Kelly S. Greer, in the hands, possession, or control of the within named garnishee, AmeriChoice Federal Credit Union at 715 Wertzville Road, Enola, Cumberland County. Pennsylvania, 17025 by handing to Allison Janosko, Branch 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 June 16, 2010 to Kelly S. Greer at 9 Oak Avenue, Enola, PA 17025. 01/05/2011 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: $95.76 January 05, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF By )Y--4? Sharon R. Lantz 0-z S-o ?.( erg 7,793 ?*--,z 53310 C ??r, m!ySuilra SheitT_ 7r.'eoso8 Ina:. r ?J - WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-7790 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From KELLY GREER, 9 Oak Avenue, Enola, PA 17025 (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: AMERICHOICE FEDERAL CREDIT UNION, 715 Wertzville Rd, Enola, PA 17025 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 $9,465.38 Interest Atty's Comm % Atty Paid $172.71 Plaintiff Paid Date: 5/26/10 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs D id D. Buell, Prothonotary B: DREQUESTING 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 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 09-7790 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s) From KELLY GREER - 9 Oak Ave., Enola, PA 17025 (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: PNC BANK - 105 Noble Blvd., 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 $9,465.38 Interest $1,086.05 L.L. Atty's Comm % Atty Paid $291.26 Plair..tiff Paid Date: 1,10/12 (Seal; REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 KOPPER BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Due Prothy $2.25 Other Costs Deputy Supreme Court ID No. 47437 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 09-7790 CIVILTERM vs. PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) KELLY GREER Defendant(s) PNC BANK 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. 7718782 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. L KELLY GREER - I Oaf ?VL° Defendant(s) Civil Action No. 09-7790 CIVILTERM ,rholA. P/154 /70.2,?- PNC BANK - 10,5- Alobl e -P/vd/ Garnishee(s) ? & /i:s /e !OW 170 3 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 KELLY GREER , Defendant 3. against PNC BANK... Garnishee 4. Judgment Amount Less Payments/credits received Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): 'l=am g - 6-0 CBF 5b ? i . 00 a2,A5 di"e Co. C 103o9d16 ?# 26896/ ? SuP? K1jr o ?it'• 5 C m.~; .? .rl ' ° ice x r 91 T? o 7v' Cn 73P C-> = a c - Q r,w, $ $9,465.38 $ $0.00 $ $1,086.05 $10,551.43 WELTMAN, WEINBERG & REIS CO., L.P.A. By: Williatn T. Molcza squire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W" No. 7718782 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 1,10,11ytitp of +?urr?firrr ? 4FFiC F F -rE ,"„RIFF it poOTHOKOTAKY Jody S Smith Chief Deputy Richard W Stewart Solicitor Discover Bank vs. Kelly S. Greer zol? FEB ` I ?m 1: 49 C 0 IINSY?--N ANIA TY IE Case Number 2009-7790 SHERIFF'S RETURN OF SERVICE 01/26/2012 11:09 AM - Ronald E. Hoover, Deputy Sheriff, who being duly swom according to law, states that on January 26, 2012 at 1107 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Kelly S. Greer, in the hands, possession, or control of the within named garnishee, PNC Bank, 105 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania 17013 by handing to Beth Ann Eppley, 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 January 27, 2012, to Kelly Greer, 9 Oak Avenue, Enola, PA 17025. SO ANSWERS, January 27, 2012 RON R ANDERSON, SHERIFF Ronald F. Hoover, Deput C, Countysuite shenff_ 7eleosott_ u?:;_ SHERIFF'S OFFICE OF CUMBERLAND COUNTY y R Anderson :riff Jody S Smith Chief Deputy Richard W Stewart Solicitor art tit' of C aejnbr,4.44 ''i j 2012 FEB 24 PM 2: a 8 CUMBERLAND COUNT',' PENNSYLVANIA Discover Bank vs. Kelly S. Greer Case Number 2009-7790 SHERIFF'S RETURN OF SERVICE 01/2612012 11:09 AM - Ronald E. Hoover, Deputy Sheriff, who being duly sworn according to law, states that on January 26, 2012 at 1107 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Kelly S. Greer, in the hands, possession, or control of the within named garnishee, PNC Bank, 105 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania, 17013 by handing to Beth Ann Eppley, 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 January 27, 2012, to Kelly Greer, 9 Oak Avenue, Enola, PA 17025. 02/24/2012 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: $87.87 February 24, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF 5'63 , :-'ol JJ(f T(le,)Soft . I nc. WELTMAN, WEINBERG & REIS CO., L.P.A. BY: James C Warmbrodt, Esquire I.D. No.42524 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 7718782 DISCOVER BANK vs. KELLY GREER and PNC BANK Garnishee(s) r ., n- Ohl 0 MAN f Attorney for Plaintiff(s) Mi F9 11: 45 "UI?E??S YlN.O VANlUN1'Y Q Cumberland County Court of Common Pleas NO. 09-7790 CIVILTERM PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter discontinued and ended as to Garnishee(s), PNC BANK, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By I hereby certify that the foregoing is a true and correct This statement is made subject to the penalties of 18 Pa.C. Warmbrodt, Esquire for Plaintiff above case. to unsworn falsifications to authorities. QaA$ L4162>-? IV q.SoPa ?