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HomeMy WebLinkAbout09-83485 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: ©9, 8 3?? vs. MICHELLE L BROWN 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 07812135 C A Pit KMJ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No MICHELLE L BROWN 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 b 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: MICHELLE L BROWN 716 N WEST ST APT 1 CARLISLE, PA 17013 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX6080 . 4. Defendant made use of said credit card and has a current balance due of $4078.51 , as of September 24, 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 September 24, 2009 . A copy of Plaintiffs 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 , MICHELLE L BROWN individually , in the amount of $4078.51 with interest at the rate of 28.990% per annum from September 24, 2009 plus attorneys' fees of $125.00 , and costs. Liames c. WELTMAN, 436 Seven Pittsburg. (412) 43 FAX: 412 07812135 .I BERG & REIS CO., L.P.A. 1 venue, Suite 1400 A 15219 55 -7130 A Pit KMJ This law firm is a debt collector attempti?to collect this debt for our client and any information obtained wi?/be used for that purpose. Now Balance Minimum Payment Due DISCOVER $752 00 Account Number ending in 6080 . ?nFc Enter Amount Enclosed Below Payment Due Date $ September 29, 2008 31 SDSN6A01 0001287 )3'' MICHEL ? LE BROWN r ? ) 716 N Will your payment get to us on time? Pa WEST ST APT 1 CARLISLE PA 17013-1924 G i1 a your bill online and your payment con be made to your account on the same day Visit Di Y scover.com/payments today. ? 4? PO BOX 6103 I??n,llnur?lnullr??„? ace CAROL Address, e-mail or telephone change? Print change in s STREAM I L 60197-6103 p above, or go to Discover.com Print your e-mail address to receive important Account information and special offers. 000001986458689829923000000000000000075200 Discover More Card Account Summary Closing Date; August 31, 2008 page 1 of 1 Account number ending in 6080 Previous Balance Payment Due Date September 29, 2008 Payments And Credits $4,078.51 Minimum Payment Due $752.00 Purchases 4,078.51 Credit Limit $3,000.00 Cash Advances + 0.00 Credit Available $0.00 Balance Transfers + 0.00 Cash Credit Limit $1,500.00 Fssance Ch s + 0.00 Cash Credit Available $0.00 - - -- - -- -- New Balance + 0.00 $0,00 Cashback Bonus Opening Cashbock Bonus Balance $ 0.00 New Coshback Bonus This Period + 000 Cashbock Bonus® Anniversary Cashback Bonus Balance S 0.00 Date: May 24 How Can We Hel You? p I . Visit Discover corn to pay yew bM for no cost view your It's your choice - 3 ways to help , latest Account information, earn and redeem rewards and more 2. Call 1-800-DISCOVER (347.2683) for F t lf Please have your Discover Card available. as , easy se -service options or to speak with a Customer Service Account Manager For TDD (assistance for hearing impaired) see reverse side 3. Write us of Discover Card, PO Box 30943, Sant Lake City, , LIT UT 841 30 i ransactions $0 Fraud Liability Guarantee Use your Discover Card with confidence. Trans. Past Dale Dab Payments and Credits Aug 31 Aug 31 INTERNAT. CHARGE-OFF •4,078.51 Finance Charge Summary Nominal 104 Average Y Doily Periodic ANNUAL PERCENTAGE ANNUAL PERCENTAGE Periodic Transaction Ba lances Rates RAT ES RA TES FINANCE FINANCE current billing period: 7days CWGES- CHARDS-- s; Purchases $0 Cash Advances $0 0.07942% 28.99% F 28.99% $0 $0 0 07942 < 28.99% F 28.99% $0 $0 The rates that aPPIY to your Account are either fixed (F) or they may vary (V) as noted above. +e it elaM IMormdlerL If there is more than one page to this billing statement see the back of each page for additional important information yea Card eember A/awrrant. Your Cardmember Agreement contains all the terms of your Account m r1r6?6er ellilell a claiillis. Reporimmediately'. Call ttea00-94 --oe29 6?e9r. Opfl vo you 9 wu eed Ore Z Pr bill Is ?epp m rd??lifa-f m rsW Ice s NUan 6 shaeft 0 days ive fen iv fl9 fd own tUM3!Ofc?1 R ale CitY.. UT 8a 130-042 asUSOaiDout a g and inrt amg6 b fdi a problem appeared. ?m an telephone e drMfar amount of the suspected error stcribe the arts and explain, if you can, why you believe there Is an error. If you need more Information, describe the Item you are unsure ado not have to aayy an amount in question while we are invesUDaUna, but wu am still bll0aled to pay the of r bill that are not in flan. While we pp Inyatl?ate your question, we pond report you aS dennquertt a take any acTfon to ealect N amount you question. iY 1?e ta Cer? toPCOtra iIf have a appmer wtth the quality of goods or services Nat you WrMased with a credit card, and, nave Ukd in faith e pmlgdUam with the merchant may rid Ifaw to pay Uw mmalrnn amount due on the moods or sconces. have this on only when tlfe purblrase ore was more Nan :y500u and the Durchase" Was made fr home state or wINDf 100 miles of mallinQ s. (If we am or operau the nerchant or If we malted you the dlverUsement for the gabds or services, all purchases are covered rdless 01 the amount or location a Durchasm p6rMa ffi on r o?malt and the too DorUOn d Nfs statement 1n the envetooe aovlded po not send cash. 8v sendin your check as rtbed autndiZ6 usk Oo u&,1A on r chec Ninaunt of he your accalnt as soon es the same day we receive your payment and you will not raefve your cheek hack from your flnanclal k slob d wur ant m be del H send cash, dens a dher Items wIN vpur payment N send the ant to atha 3 a tt vt ofvm an envaeviaos the f the one aw?detl. cots receivatl on a attar t PM ffi dui pros sine tacflit kWhdav h Fri or on a rreew ktearle a Dank frolldav will be bested to ?oyr A rat as d the next ?rusinas d. If vau have mi aacedlr envel6oe. r payment to Discover Bank, PO Uac 6 i 03 Card,". Sueam, i a0 i 97-6103. floase allow 10 days f r dativery. If your paym t is retumdd 1 we reserve Ure rlant to resubmit it as an electranc debit w, Sa_pyy your•migifnum payment a,a preafer pmount.Qver the teephone, and you coq set uD ttutanaUC pavmonts. GII us at 1-800.347-2663, n -11- -%r man will w maw anu now mucn it writ w. rout aummauc payment amount may be less Than on them thly statement redits or payments applied during the billing cycle. We report information about yyoouur account to credit bureaus. Late ymants, misseO payments, or other defaults on ur raDyL f?ecte0lon your cedit XWe nFM I dthe staatlr1 and jK ii:WD of your AccDUnt to Cladit remrtln nCla each 1 OE address: Discover Ca gap t 15AMIlmington. I--631. teh?ridadet our name, Mess rhgncoerrft?dne num'oer reandaAt thoe f0nt r. hied Mr Paelresa (at Nast 25 ). We begin to Impose Periodic Finance Char on all transactions from the Transaction. Date for the On as shown an r Itin s t unless a transa Nat cil in is posted to r Ac . t after the clos of othe i dllin??o?p?rfod in pwohich it occurs, Me we nu W Im fnance Chames on transaction Ne flnt 1W /?flance bill rtakin rents of rtlcavinq clbOlls. We epnU to Im c inane Charge until the data r entire NeW It you paid the ante on vour previous Ili no statement a ent Due Date sham a mat d n taremwat sad .an. aa? rn. purchases nrst-appearing on the current billing statement W6 call this the "grace period." Them is no grace pedod'on balance transfers or cash' advances. L kNrlNaen Fhrar?e Chwo. We will MarDe you a minimum FINANCE CHARGE of $.50 for any billing period in which Periodic Finance Charges of less than CO would othbrwise be impose0 Areegl Fee. If your Account has an annual fee It will be billed at N nnin of each annlversa year r Account is open. The amount of the fee appears on the statement when the fee is billed. The annual fa iS not rfundade unless voryU noUt)/ us that you wish to close your Aarount ,thin ?I s of the mallirg or A? r° dale M t^e s a emenf nr wh'.cn the lee is billed °ou wiR receive this refund even if you use your Card uwmg uraT penoo. PerINC Flov Chow We sort your transactions into #rouT o1exarchases, cash advances and balance transfers and then further sort the transactions within scrt rou by Nor Annual Percentge Kate. For macilde. purchases suD1act to a promotional rate and purchases sub ect to a sterndab rae l be gps We refer to these pproves as trans on w ies At he and of each dllin period, we compu% balances rid Perioditc Financed wou h a eachrouday of the billing period fa each transaction ory. We use the dlowlng ?q align to compute Periodic inane Charges for each saMon category. Average Daily Balance) times (days in billing period) times (Daily Periodic Rate) t{{You maayy refer to the finance MarDe summary on ur dllfn statement for N amounts.) Then we add u the Periodic Finance Charges for each VansacUDnf to pet the total Periodic Finance Charpesa for your Aocount The Average Daily Balance I? shown as zero if, because d the grace pen no boOfc F to the balance I a transactio inalise Charges n ca s e use the A Dail Bala cea?pnpl udinu new transactions) metho dd c Ic IaUn the lance urn, which we impose Periodic Finance Changes We comNe DaflY ?lanpe for each transaction le oorv by addf?s up all the daalances in a Dillina penal for a Vans on t and diNdln a teal by the number of dais in Ne blllirtg r',erlod. We comfu to 'he daftflance for ?Cn transaction category pn each daycapy i n the lowing to the aeylpus day s Dally balance: nsactfons with Tmnsac0oX to of that day as shown on your dllin statifinenl unless trte transaction is posted to your Adcount attar the close of the billing9 nod in which it occurs, in t?hich case the transaOCUon w1II be to the daily balance as of the first day of the billing xnod in whiclf It is posted tp your Account, fees charged that day and Periodic Finance Charges accrued on the preA da s daily balancearia b then subtracting any cmdit3 and payments that art addled fnst the balanc?e d Na nsaetion ca on Nat d Inc IculaUn the da y balance fa the first of the Wiling9 opaenlobi, we co filer the agaeavipus days daily ltalance" tp have Ur balance a aeh tmnsa on W a Ne last day r pus DiRln nod. Alt fees ctl to yvoouur Account am add to Ne star rd Wmhase Uansactiai ca wIN the ex UQri of Cxh A ?Ce Transaction Fa aroa?mawdhrcn h Irian Ge Ch are added to the aoollcade Cash adverse Vansacllon category a d lance Tmns?TransacUon f a Finance Charges whic are added tpTne apWicade Oalance Vanafbr VansaCUOn ca When Ne soeclab rate expires, we moue the unpaid balance of Ne balance trans/a and lne- Balancq Tnnstar Transactor Fee Finance C err _ to. ire standarO purchase tmnsacbon calegay. Hortever, if the special rate has z For TOO (TeleeanrerpeMfees DeNee for Lie Deal) aseletence, please call 1-900-947-7449. 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 Manaizer _ 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. (Signature) WWR# 7812135 Michelle L. Brown '6011002557156080 RED- 7 ? 07 2C?9CLC-3 ?,'•?1?? C r. , k M { tk 14- l/ 3'? 3 ? 7 / ~r '!'•- ) I Y~~Y 2~1Q~`~r't't" 27 PIS i:..3Q ~ .A r~L~:. J~~,~CV~ iN DISCOVER BANK Plaintiff vs. MICHELLE L BROWN Defendant IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION No: 09-8348 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 07812135 C A Pit DIP Judgment Amount $4965.62 ~I~.op ~p A1Tf ~~# 4la0~583 ~~ a~ a~~~ I V o~tC~ ~1.~~.1,~r~ DISCOVER BANK Plaintiff vs. MICHELLE L BROWN IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Civil Action No. 09-8348 NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that t e following Order of Judgment was entered against you on ~ a7 (xx) Assumpsit Judgment in the amount of $4965.62 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 Prothonotary BY ~ LS' /^ ~~~.tst~G ~ ~ /i e i i~.v iaivi9V 1L1Lt1 , J MICHELLE L BROWN 716 N WEST ST APT 1 CARLISLE, PA 17013 Plaintiff's address is: C/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 ' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. MICHELLE L BROWN TO THE PROTHONTARY: Civil Action No. 09-8348 PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant MICHELLE L BROWN above named, in the default of an Answer, in the amount of $4965.62 computed as follows: Amount claimed in Complaint Less payments / adjustments made $4078.51 $0.00 Interest on the remaining principal balance of $4078.51 from September 24, 2009 to May 18, 2010 @ the interest rate of 28.9900 per annum $762.11 Attorney's fees $125.00 TOTAL $4965.62 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./ W~mbrodt, 425 07812135 ~ 1~, Pit DIP Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburg A 15219 And that the last known address of the e endant is MICHELLE L BROWN 716 N WEST ST APT 1 CARLISLE, PA 17013 IN THE COURT OF COMMON PLEAS CUMBERI,~INQ COUNTY, I?ENI~ISX(.V.~1NIA CIVIL DIVISIOIU pISGQVt=R ~/~NK 1~I~igtiff vs. MICHELLE L BROWN Defendant Ca3~s No. Q9-$348 1~ TO: MICHELLIr L DROWN 716 N WEST ST APT 1 CARLISLE, PA 17013 Dat® of 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 C)F 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 NAVE 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, W INBERG &REIS CO., L.P.A. By: Matthew~Urbata _ _ _ . P.A.LD.# 90963 WELTMAN, WEINBERC &REIS CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-79b5 7Z~12135 A PIT 1`4L ' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 09-8348 NON-MILITARY AFFIDAVIT MICHELLE L BROWN 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 MICHELLE L BROWN 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 DMDC does not possess any information indicating the individual status. MICHELLE L BROWN 716 N WEST ST APT 1 CARLISLE, PA 17013 is not in the military service. Further Affiant sayeth naught. Reclpe~t ~r IUlilitary ~tatu Departnraent of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Belief Act He~~ ~ of IY~a~t-~4~-~~ 10 1 Q:18; Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency BROWN MICHELLE Based on the information you have furnished, the DMDC does not possess L an information indicatin the individual status. 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 Uniformed Services (Army, Navy, Marine Corps, Air Force, NUAA, Public Health, and Coast Guard). ~~ ~-~- Mary M. Snavely-Dixon, Director Department of Defense ~ Manpower Data Center 1G00 Wilson Blvd., Suite 400 Arlington, VA ~~~OQR2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEEDS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as 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 status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink.mil/faq/pis/PC09SLDR.html. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App, §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DQB, 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 active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points•of contact. hops;//wv~c.dxndc.~~d~mil~ap~1/s~ralp~preport,dc~ 5/~~#/~Q 1 R~~u~~t ~1?x ilit ~~~tu~ ~'~~~ ~ ~! t~Pt:~ z~.r,~~tr~ ate csA~~t~N~ ~~~ ~~s ~` Active duty status as r-sported in this certificate is defined in accordance with 1 ~ UDC ~ 1 d 1(d)(l) for a period of more than 30 consecutive days. In the ease of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC ~ 50~(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGI~.) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARS, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public I~ealth Service or the National oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 3Q consecutive days, coverage Under the ,SCl~4 is ~ruader in Same Cases Coverage under the SCRA is broader in some cases and includes some categories of per-sons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would ea~tend SCRA protections. Persons seeking to rely on this website certification should cheek to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extensi beyond the last dates of active duty. Those who would rely on this certificate are urged xa seek qualified legal counsel to ensure that all rights guaranteed tQ Service members under the SCI~A, are protected, WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report 113:MFN9BTR61 P hops:l/y~yu!,dmc~c.o~d,rr~illappa/scralpQp~~pQrt,dt~ 5/~4/2Q 14 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor s .. oF,'IGEOF THE S ,ERIFF FILED-OFFICE OF T NE PR0TR0I,!0TA;RY 2011 MAY 31 AM 9: 02 CUMBERLAND COUNT)' PENNSYLVANIA Discover Bank Case Number vs. Michelle L. Brown 2009-8348 SHERIFF'S RETURN OF SERVICE 05/19/2011 09:35 AM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on May 19, 2011 at 0930 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Michelle L. Brown, in the hands, possession, or control of the within named garnishee, Sovereign Bank, 17 W High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Julie Myers, 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. 05/19/2011 09:35 AM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on May 19, 2011 at 0932 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Michelle L. Brown, in the hands, possession, or control of the within named garnishee, M & T Bank, 1 W High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Donna Egolf, Teller, 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. 05/23/2011 02:48 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on May 23, 2011 at 1437 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Michelle L. Brown, in the hands, possession, or control of the within named garnishee, Wells Fargo Bank NC, 604 E High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Danielle Hom, Teller, 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 May 25, 2011 to Michelle L. Brown at 716 N West Street, Apartment 1, Carlisle, PA 17013. SO ANSWERS, May 25, 2011 Ronald Hoover, Deputy RON R ANDERSON, SHERIFF Rob rt Sitner, Deputy (c) CountySUIle Shenff. Te!eosoft Inc. WELTMAN, WEINBERG & REIS CO., L.P.A. BY: James C Warmbrodt, Esquire Attorney for Plaintiff(s) I.D. No.42524 436 Seventh Avenue, Suite 1400 --? Pittsburgh, PA 15219 rnrn G Phone: 412.434.7955 Ln Fax: 412.434.7959 T> -? File # 7812135 Lp -0 p-4 ° rra DISCOVER BANK CIN Cumberland County Court of Common Pleas vs. MICHELLE L BROWN NO. 09-8348 and SOVEREIGN BANK WELLS FARGO BANK and M&T BANK Garnishee(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter discontinued and ended as to Garnishee(s), SOVEREIGN BANK WELLS FARGO BANK and M&T BANK, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By Sworn to and subscribed Before me the IS-day ofgne, 2011 Y PU COMMONWEALTH OF F1?i'+' V'- VANTA Notarial Sea3 Wayne A. Jones, Notery Public City of Pittsburgh, Alicgheny County My Commission Ex Tres June 29, 2014 Me rr: PIL floviva "10 Apowlot q? MaMari?R RruF @ 8.0o j? 7?.a (?,Ib18