HomeMy WebLinkAbout09-8033IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff No: oQ -e633
vs.
COMPLAINT IN CIVIL ACTION
SEAN D HARPER
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
07794343 C A Pit KMJ
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No
SEAN D HARPER
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:
SEAN D HARPER
16 W GLENWOOD DR # A
CAMP HILL, PA 17011
3. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXX6233 .
4. Defendant made use of said credit card and has a current balance
due of $9800.79 , as of September 12, 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
28.9900 per annum on the unpaid balance from September 12, 2009 . A
copy of Plaintiff's Statement is attached hereto, marked as Exhibit
111" 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 , SEAN D HARPER individually , in the amount of
$9800.79 with interest at the rate of 28.990% per annum from September
12, 2009 plus attorneys' fees of $125.00 , and costs.
James C. Warmbrodt,42524
WELT WEINBERG & REIS CO., L.P.A.
436 Se e th Avenue, Suite 1400
Pitts ur h, PA 15219
(412) 4 4-7955
FAX: 4 2-338-7130
0779 43 C A 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.
Ulla .."_?b CK 50.00 sll 976.00
CARD
Payment Due Date
August 26, 2009
Enter Amount Enclosed Below
?g3g3
31 SDSN6A01 0001619
SEAN HARPER
16 W GLENWOOD DR # A
CAMP HILL PA 17011-1138
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.
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 111111111111111111111111
CAROL STREAM IL 60197-6103
000001986458919117677000000000000000197600
Discover More Card Account Summary
Closing Date; July 31, 2009 page 1 of 1
Account number ending in 6233 Previous Balance $9,800.79
Payment Due Date August 26, 2009 Payments And Credits 9,800.79
Minimum Payment Due $1,976.00 Purchases + 0.00
Credit Limit $7,800.00 Cash Advances + 0.00
Credit Available $0.00 Balance Transfers + 0.00
Cash Credit Limit $4,000.00 Finance Char e? s + 0.00
Cash Credit Available $0.00 New Balance = $0.00
Cashback Bonus® Opening Cashback Bonus Balance $ 0.00
New Cashback Bonus This Period + 0.00
Cashback Bonus Balance $ 0.00
Cashback BonusS Anniversary - - . - - - - -
Date: November 10
How Can We Help
P You? 1. Visit Discover.com to pay your bill for no cost, view our
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It's your choice - 3 ways to help a
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ccoun
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and more
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
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 $ -9,800.79
h.
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: 21 days
Purchases $0 0.07942% 28.99% F 28.99% $0 $0
Cash Advances $0 0.07942% 28.99% F 28.99% $0 $0
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
0
Lost or stolen cards. Report immediately! Call 1-800-347-2683. Z
m
Billing 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, Sall 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 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: o
.Your name and Account number. rn
.The dollar amount of the suspected error. A
.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 N
about 0
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 good faith to correct the problem with the merchant, you may not have to pay the remaining amount due on the goods or
services. You have this protection only when the purchase price was more than $50 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
olhcr address or rl ou use an envelope other th6,, °. c,ne p,ovod , vn'enls received of or sifter 1 ?'A , 1o, flay throw f-F vtay-or on-3 weefcsnd
or bank holiday ""I/be posted to yow Account as of the next business day If you have misplaced your envelope, sen2your payment to Discover
Bank, PO Box 6103, Carol Stream, L 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 yyour 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 coedit 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 payment, however we must receive notice at least three business days in advance of the scheduled payment You
may notify us by phone at 1.800.347-2683 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 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. We normally report the status and payyment history of your Account to credit reporting agencies each
month If you believe that our report is inaccurate or incomplete, please write us at tf a 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 the Payment Due Date shown on that statement, and you pay he 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 srparate
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 penod for each transaction category We use the following equation to compute Periodic Finance Charges for each
transaction category: Avenge Daily Balance x number of days in the billing period x Daily Periodic Rate (You may refer to the finance charge
summary on your billing statement for these amounts) Then we add up theFeriodic 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 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 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 brllrng statement,
as well as new purchases that first appear on the current billing statement, unless we already imposed 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 daily balances in a billing period for a transaction category
and divitlinq the total by the number of days in the billing cycle. We compute the daily balance for each transaction category on each day byIiIst
adding the following to the previous day's daily 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 daily 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 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 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 a special balance transfer rate expires, we move the unpaid balance of the
balance transfer and the Balance Transfer Transaction Fee Finance Charges to the standard purchase transaction category. However, if the special
rate has been terminated under the Default Rate Plan, we leave the unpaid balance of the balance transfer and the Balance Transfer Transaction Fee
Finance Charges in the applicable transaction category until the special rate would have expired.
r- Tnn lTslnr -,.I-fI.ne nnvlr• fnr fhn rlnafl aetl.tanr. nl?at• call 1_Rnn.9d7.7dd9
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to
unsworn falsifications to authorities, that she is Tinisha Williams
(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.
WWR# 7794343
Sean D. Harper
'6011002806366233
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SHERIFF'S OFFICE OF CUMBERLAND COUNTY
R Thomas Kline _• :.. _
L
Sheriff ri
r r T' ~~~
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Ronny R Anderson
Chief Deputy 2C'('~ ~ - f ^• [
Jody S Smith
Civil Process Sergeant ~'~` ~ ` ~`• ~`"=~'~~ r'
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Edward L Schorpp ' '
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Solicitor
Discover Bank Case Number
vs. 2009-8033
Sean D. Harper
SHERIFF'S RETURN OF SERVICE
11/24/2009 06:59 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on
November 24, 2009 at 1859 hours, he served a true copy of the within Complaint and Notice, upon the
within named defendant, to wit: Sean D. Harper, by making known unto himself personally, at 16 W.
Glenwood Drive #A, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same
time handing to him personally the said true and correct copy of the same.
SHERIFF COST: $41.50
November 25, 2009
SO ANSWERS,
~i~~'~C ~aEs•~I
R THOMAS KLI~~, SHERIFF
BY
Sher
t_ rr ~~~:>~ rr i~,~:
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 09-8033 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s)
From SEAN D. HARPER, 16 WEST GLENWOOD DRIVE #A, CAMP HILL, PA 17011
(1) You are directed to levy upon the property of the defendant (s)and to sell
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
METRO BANK, 20 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 $11,054.50
L.L.$.50
Interest $1,404.05
Atty's Comm %
Atty Paid $165.50
Plaintiff Paid
Due Prothy $2.25
Other Costs
Date: April 9, 2012
(Seal)
REQUESTING PARTY:
Name WILLIAM T. MOLCZAN, ESQUIRE
-Ia4m-4?1 -?
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 CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No. 09-8033 CIVIL TERM
SEAN D HARPER 1l
Defendant(s)
METRO BANK a (?jb 1e ?U4. l.?" t? S K < TO 7L) 3 W
Garnishee(s) rqw
PRAECIPE FOR WRIT OF EXECUTION -
7?1 77
r
TO THE PROTHONOTARY:
> c-:, -;
Kindly issue a Writ of Execution in the above matter... --
1. directed to the Sheriff of CUMBERLAND County: y? ° {
2. against SEAN D HARPER , Defendant
3. against METRO BANK... Garnishee
4. Judgment Amount $ $11,054.50
Less Payments/credits received $ $0.00
Interest $ $1,404.05
Costs $
SUBTOTAL: $ $12,458.55
Costs (to be added by Prothonotary): $
WELTMAN, WEINBERG & REIS CO., L.P.A.
By: 4??- / v---_
William T. Molczan, Esque
$ Ol , Ob 0 PA I.D. #47437
a
C -Is ? ? ? ? WELTMAN, WEINBERG & REIS CO., L.P.A.
w a 1400 Koppers Building
??. !S 436 Seventh Avenue
O° " 5 Pittsburgh, PA 15219
9. SO (412) 434-7955
SC
C 4- ' u? S W WR No. 7794343
?a73H?r'r;`
6(
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
SEAN D HARPER
Defendant(s)
METRO BANK
Garnishee(s)
No. 09-8033 CIVIL TERM
PRAECIPE FOR WRIT OF EXECUTION
(BANK ATTACHMENT ONLY)
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
W" No. 7794343
0 PV'
"%?F? 17 f*;ll?:?
iJMBERLAND COIUNNT a'
IN THE COURT OF C8P*§ 4MAOF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
SEAN D HARPER
Defendant(s)
METRO BANK
Garnishee(s)
Civil Action No. 09-8033 CIVIL, TERM
T'fi?'j P-Is
INTERROGATORIES IN ATTACHMENT
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. 7794343
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
SEAN D HARPER
Defendant(s)
METRO BANK
Garnishee(s)
Civil Action No. 09-8033 CIVIL TERM
TO: METRO BANK, 20 NOBLE BLVD, CARLISLE, PA 17013
RE: SEAN D HARPER, 16 W GLENWOOD DR # A, CAMP HILL, PA 17011
Suggested Reference No.: XXX-XX-6174
XXX-XX-
IMPORTANT NOTICES TO GARNISHEE!
A. You are required to file answers to the following interrogatories within twenty (20) days after
service upon you. Failure to do so may result in Judgment against you.
B. Herein, the word "defendant" means any one or more of the defendants against whom the writ of
Execution is issued.
C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to
attachment which is then in the hands of the garnishee, it also attaches all property of the defendant which comes
into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For example, the
resultant liability of a Garnishee-Bank would not be measured by the balance in the debtor's account, either at the
time of service of the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited
and withdrawn during the intervening period.
WWR No. 7794343
INTERROGATORIES IN ATTACHMENT
1. At the time you were served or at any subsequent time did you owe the defendant any money or
were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money
or were liable to him for any reason (including funds on deposit for checking or savings accounts and certificates of
deposit)?
No Accounts
l a. If the answer to Interrogatory 1 is in the affirmative, state the following: the amount
of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof;
the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written
instruments and the present location of each of such instruments; the amount or amounts that defendant claims or
claimed that you owe or owed to him; and the nature and amount of each of such liabilities.
2. At the time you were served or at any subsequent time was there in your possession, custody or
control of yourself and one or more other persons any property of any nature owned solely or in part by the
defendant.
3. At the time you were served or at any subsequent time did you hold legal title to any property of
any nature owned solely or part by the defendant or in which defendant held or claimed any interest?
4. At the time you were served or at any subsequent time did you hold as fiduciary any property in
which the defendant had an interest?
5. At any time before or after you were served, did the defendant transfer or deliver any property to
you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof?
6. At any time after you were served did you pay, transfer, or deliver any money or property to the
defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the defendant
against you?
7. If you are a bank or other financial institution, at the time you were served or at any subsequent
time did the defendant have funds on deposit in an account in which funds are deposited electronically on a
recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or
attachment under Pennsylvania or federal law? If so, Identify each account and state the reason for the exemption,
the amount being withheld under each exemption and the amount of funds in each account, and the entity
electronically depositing those funds on a recurring basis.
WWR No. 7794343
8. If you are a bank or other financial institution, at the time you were served or at any subsequent
time did the defendant have funds on deposit in an account in which the funds on deposit, not including any
otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 8123? If
so, identify each account.
9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these
interrogatories on this institution.
10. If the answer to Interrogatory 1 is in the affirmative, state the date the written instrument, checking
or savings account, certificate of deposit, or other funds were frozen, restricted, or otherwise put on hold by this
institution.
11. If the response to Interrogatory 7 is in the affirmative, are other funds comingled in the account
which are not deposited electronically on a recurring basis and which are identified as being funds that upon deposit
are exempt from execution, levy or attachment under Pennsylvania or federal law?
12. If the response to Interrogatory I 1 is in the affirmative, state the amount of non-exempt funds on
deposit in the account.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
William T. Molczan, Esquir
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. 7794343
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA. C.S. § 4904 relating
to unworn falsifications to authorities, that he/she is Jennifer Hilbish
(Name)
Levy Specialist of Metro Bank, garnishee herein,
(Title) (Company)
that he/she duly authorized to make this verification, and that the facts set forth in the foregoing
Answers to Interrogatories are true and correct to the best of his/her-ii;,owledge, information and
belief.
RTC4mAT R FI
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
3?l
31
00
EsflSYL'"N
Discover Bank
vs.
Sean D. Harper
Case Number
2009-8033
SHERIFF'S RETURN OF SERVICE
04/13/2012 02:47 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on April 13,
2012 at 1447 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies
of the within named defendant, to wit: Sean D. Harper, in the hands, possession, or control of the within
named garnishee, Metro Bank, 20 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania 17013, by
handing to Darijo Celikovic, Customer Service 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, 2012 to Sean D. Harper at 16 W
Glenwood Dr, #A, Camp Hill, PA 17011.
SO ANSWERS,
?
""
? ? ?? ? r?l ? ?
April 17, 2012 R-01\109 R ANDERSON, SHERIFF
a uts all, Deputy
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 # 7794343
DISCOVER BANK
vs.
SEAN D HARPER,
and
METRO BANK
Garnishee(s)
Attorney for Plaintiff(s)
CUMBERLAND County
Court of Common Pleas
NO. 09-8033 CIVIL TERM
PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION
TO THE PROTHONOTARY:
1 t ? 7 ?I f;?? ht (, _?
30
ND C
. VA NIA
Kindly mark the above matter discontinued and ended as to Garnishee(s), METRO BANK,,
only.
WELTMAN, WEINBERG & REIS CO., L.P.A.
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.
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a'7 v(/yo
SIHERIFF'S OFFICE OF CUMBERLAND COUNTY
Anderson ii^~~J- ~)r ~ ,u_
:s5'+`4~~' l k~tarEf+3~r~~ ~ 'i', ~~{{Z I ~'`~."`
..
S Smith !~~~~ ~~~ _~ I~t"~ ~: ~?~i
ief Deputy
Richard W Stewart !,~T`"~~~;d~.r` ~'U l.~i.i.s'
solicitor r~EN??S Yp..'~~ FBI r ~.
Discover Bank I Case Number
vs. 2009-8033
Sean D. Harper __.__.___
SHERIFF'S RETURN OF SERVICE
04/13/2012 02:47 PM -Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law,. states that on April
13, 2012 at 1447 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and
monies o~f the within named defendant, to wit: Sean D. Harper, in the hands, possession, or control of the
within named garnishee, Metro Bank, 20 Noble Boulevard, Carlisle, Cumberland County. Pennsylvania
17013, by handing to Darijo Celikovic;, Customer Service Representative, personally three copies of
interrogal:ories 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, 2012 to Sean D. Harper at 16 W
Glenwood Dr, #A, Camp Hill, PA 17011.
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 92 SO ANSWERS,
/~~,'`7
November 07, 2012 RON R ANDERSON, SHERIFF
~~~ ~~ 9~
WELTMAN,WEINBERG&REIS CO.,L.P.A.
BY: William T Molczan,Esquire Attorney for Plaintiff(s)
I.D.No.47437
436 Seventh Avenue, Suite 1400
Pittsburgh,PA 15219 —t
Phone: 412.434.7955 r"
Fax: 412.434.7959 'ar
File# 7794343 ► oC)
s c,-"
DISCOVER BANK
Plaintiff . p
CUMBERLAND County
Court of Common Pleas
VS.
NO. 09-8033 CIVIL TERM
SEAN D HARPER
Defendant(s)
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.
WELTMAN, WEINBERG&REIS CO., L.P.A.
By
William T IVA-
Iczq*Esquire e
Attorney for Pl ' iff