HomeMy WebLinkAbout10-1462FI4F THE MI IO IOTARY
2010 MAR -2 AM 11 : 20
I'E1 gtJSY!_VAN11A
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
PATRICK A BASOM
Defendant
No : !D -
COMPLAINT IN CIVIL ACTION
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
08055510 C A Pit KMJ
Q
0l2 .0o ?cL1DrJr"k1
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No
PATRICK A BASOM
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:
PATRICK A BASOM
103 N 21ST ST
CAMP HILL, PA 17011
3. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXX5949 .
4. Defendant made use of said credit card and has a current balance
due of $6272.34 , as of December 26, 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 December 26, 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 , PATRICK A BASOM individually in the amount of
$6272.34 with interest at the rate of 28.990. per annum from December
26, 2009 plus attorneys' fees of $125.00 , and costs.
James C.
WELTMAN,
436 Sev
Pittsbu
(412) 3
FAX: 4 2
08055 1C
This law firm is a debt collector attemp
our client and any information obtained y1il
a m ro t,42524
WE NBERG & REIS CO., L.P.A.
.th Avenue, Suite 1400
h PA 15219
- 955
38-7130
C A Pit KMJ
to collect this debt for
be used for that purpose.
cam' ??j1gL' :r Y $6,272.34 $6,272.34 Enter Amount Enclosed Below
- CARD
-_.------------
Payment Due Date
--.,.J
$
May 14, 2009 Please make check payable to Discover Card.
Minimum payment due includes a past due
amount of V,319.00.
15 ';[),IN( A01 0001272
PATRICK BASOM,' Will your payment get to us on time? Pay
103 N 21 ST ST your bill online and your payment can be
CAMP HILL PA 17011-3809 made to your account on the same day. Visit
Discover.com/payments today.
PO BOX 6103 11111111111111 1 loll 1111111 11
CAROL STREAM IL 60197-6103
address, e-mail or telephone change? Print change in space lrllrrllrrriirlllrlrrlrrrlillrrrrillllrrirrllrllrrrirllrrlrrll
cbovs, or go to Discover.com. Print your e-mail address to
nmei ie important Account information and special offers.
1100001986458433369549062723400000000627234
Discover More Card Account Summary
Closing Date: April 15, 2009 page 1 of 1
Accomt number ending in 59,49 Previous Balance $6,272.34
Piymant Due Date May 14, 2009 Payments And Credits 0.00
Mininwm Payment Due $6,272.34 Purchases + 0
00
Credit Limit $6,600.00 Cash Advances .
+ 0
00
Credit Available $0.00 Balance Transfers .
+ 0
00
Cash Credit limit $0.00 Finance Charges .
+ 0
00
cash Credit Available $0.00 New Balance .
= $6,272.34
&,aShback Bonus® Opening Cashback Bonus Balance $ 0.00
New Cashback Bonus This Period + 0.00
Cashback Bonus Balance $ 0.00
C ishback Bonuse-,Anniversary
1A3te: September 15
How Can We Help You? 1. Visit Discover.com to pay your bill for no cost, view our
I? latest Account information, earn and redeem rewards and more
It's your choice - 3 ways to help 2. Call 1-800-DISCOVER (347-2683) for fast, easy self-service
Please have your Discover Card available. options or to speak with a Customer Service Account Manager
For TDD (assistance for hearing impaired) see reverse side 3. Write us at Discover Card, PO Box 30943,
Salt Lake City, UT 84130
Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence.
Information For You
While we are permitted under the Cardmember Agreement to increase the APRs on your Account because your payment
wcis late, we have chosen not to do so at this time. We have terminated, however, any introductory or promotional rate on
purchases and any special balance transfer rate, and applied the standard APR for purchases to your outstanding balance of
purchases and balance transfers. However, we reserve the right to increase the APRs on your Account if you fail to pay the
minimum payment due by the payment due date. See the Default Rate Plan section of the Cardmember Agreement for
details.
I -
Finance Charge Summary
Nominal Transaction
Average Daily ANNUAL ANNUAL Periodic Fee
i Daily Periodic PERCENTAGE PERCENTAGE FINANCE FINANCE
Balances Rates RATES RATES CHARGES CHARGES
current billing period: 31 days
Purchases $0 0.07942% 28.99% F 28.99% $0 $0
Cash Advances $0 0.07942% 28.99% F 28.99% $0 $0
previous billing period: 28 days
Purchases $0 0.07942% 28.99% F 28.99% $0 none
The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above.
Important Information. If there is more than one page to this billing statement, see the back of each page for additional important information.
See your Cardmember Agreement. Your Cardmember Agreement contains all the terms of your Account
Lost or stolen cards. Report immediately! Call 1-800-347-2683.
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
transaction on your bill, write us on a separate sheet of paper at Discover MoresM; PO Box 30421, Salt Lae 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
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.
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 mayy 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 pament, 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 P4 Monday 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 envelope, send your payment to
Discover Bank, PO Box 6103, Carol Stream, IL 60197.6103. Please allow 7.10 days for delivery If your payment is returned unpaid, we reserve the
right to resubmit it as an electronic debit.
You can pay your minimum payment or a greater amount over the telephone, and you can set up automatic payments. Call us at 1.800-347.2683.
You will need leis statement and your bank account information. You must ensure that sufficient funds are available in your bank account, and all
transactions must comply with U.S. law You will be asked to provide the first 5 digits of your account statement zip code. By entering those
numbers as your electronic signature, you will be agreeing to this authorization to allow us and your bank to deduct each payment you authorize
from your bank account, and to initiate debit or credit entries to your bank account, as applicable, to correct an error in the processing of such
payment You must tell us the amount of each payment, or you can select an amount such as the Minimum Payment Due or the New Balance on
each statement You can cancel a 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 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 We normally report the status and payment history of Your Account to credit reporting agencies each
month. If you believe that our report is inaccurate or incomplete, please write us at the following address: Discover MoresM Card, PQ 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, we will provide the following "grace period." If
you paid the New a ance on your previous billing statement by the Payment Due Date shown on that statement, and you pay the New Balance by
the Payment Due Date on this statement, we will not impose Periodic Finance Charges on new purchases, that is, purchases first appearing on this
statement. Otherwise, you will receive a billing statement next month that includes Periodic Finance Charges on those new purchases. There is no
grace period on balance transfers or cash advances.
We sort your transactions into for 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 prootional 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 Dal y Balance x number of days in the billing period x Daily Periodic Rate. (See he finance charge summary on your statement for
these am.unts.l Then we add up the Periodic Finance Charges for each transaction category to get the total Periodic Finance Charges for your
Account. The Average Daily Balance is shown as zero if, because of the grace period, no Periodic finance Charges apply to the balance In a
transaction category.
We use the two-cycle. average daily 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 billing 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 dividing the total by the number of days in the billing cycle. We compute the dally balance for each transaction category on each day by first
adding the following to the previous day's daily balance. transactions made that day, feet 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 previous billing period, we consider the "previous day's daily balance" to have been zero on the
first day oT the 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 categtory. 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 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.
For Tnn ITelnmmnmonieatirmt neviee Mr the nrart attittanr?. nleate rail 1_Rnn.147_711Q
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 James Ball
(Name)
Team Lead -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.
WWR# 8055510
Patrick A. Basom
'6011002310735949
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Edward L Schorpp
SOIICItOr
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fll.~D-~r~CE
tJF tHr p~?p,,,":w~TARY
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Discover Bank
vs.
Patrick A. Basom
Case Number
2010-1462
SHERIFF'S RETURN OF SERVICE
03/17/2010 08:27 PM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on
March 17, 2010 at 2027 hours, she served a true copy of the within Complaint and Notice, upon the within
named defendant, to wit: Patrick A. Basom, by making known unto Patricia Basom, Mother of defendant
at 103 N. 21st Street, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same
time handing to her personally the said true and correct copy of the same.
i
AMANDA COBAUGH, DEPU
SHERIFF COST: $41.50
March 18, 2010
SO ANSWERS,
RON R ANDERSON, SHERIFF
,ci CountySulte Sh~rK~. Te:~nosuft. Inc.
i l'" ~r. .rte
2~ e~ MIAAY 2 I PM 2: 4 I
~,
-~~JTY
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Ib- (~lo~
Plaintiff No: ''_^~T-CIVIL TERM
vs.
PATRICK A BASOM
PRAECIPE FOR DEFAULT JUDGMENT
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
08055510 C A Pit KMJ
Judgment Amount $7047.93
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No. 10-142 CIVIL TERM
PATRICK A BASOM
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONTARY:
Kindly enter Judgment against the Defendant PATRICK A BASOM above named,
in the default of an Answer, in the amount of $7047.93 computed as follows:
Amount claimed in Complaint
Less payments / adjustments made
Interest on the remaining principa
$6272.34 from December 26, 2009
Q the interest rate of 28.990%
Attorney's fees
TOTAL
$6272.34
$0.00
1 balance of
to May 06, 2010
per annum $650.59
$125.00
$7047.93
I hereby certify that appropriate Notices of Default, as attached have
been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the
Notices.
WELTMAN, WEINBERG & REIS CO., L.P.A.
James C . rm~t",
08055510 C Pj Pit KMJ
Plaintiff's address is:
c/o WELTMAN, WEINBERG & REIS CO., L.P.A.,
436 Seventh Avenue, Suite 1400 Pittsbur A 15219
And that the last known address of the endant is
PATRICK A BASOM
103 N 21ST ST
CAMP HILL, PA 17011
~I~, oo PAD Am/
C~' 45$c~G(v5
~,~ a~a-Ug3
I~~cee, ~•lo~c~-~
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
PATRICK A BASOM
Civil Action No. 10-142 CIVIL TERM
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that th~ f~llowing Order of Judgment
was entered against you on ~ oZ.l /!C
(xx) Assumpsit Judgment in the amount of $7047.93 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
Prothono
By:
PATRICK A BASOM
103 N 21ST ST
CAMP HILL, PA 17011
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. Civil Action No. 10-142 CIVIL TERM
PATRICK A BASOM
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 PATRICK A BASOM 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.
PATRICK A BASOM
103 N 21ST ST
CAMP HILL, PA 17011
is not in the military service. Further Affiant sayeth naught.
Request for Military Status
Department of Defense Manpower Data Center
:Military Status Report
~ Pursuant to the Service Members Civil Relief Act
~~
Page 1 of 2
May-13-2010 09:14:02
`~`. Last
Name
First/Middle
Begin Date
Active Duty Status
Active Duty End Date Service
Agenc
Y
BASOM PATRICK Based on the information you have furnished, the DMDC does not possess
any information indicating 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, NOAA, Public Health, and Coast
Guard).
~ ~,-~
Mary M. Snavely-Dixon, Director
Department of Defense -Manpower Data Center
1600 Wilson Blvd., Suite 400
Arlington, VA 22209-2593
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that
maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the
official source of data on eligibility for military medical care and other eligibility systems.
The 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/f~/Ris/PC09SLDR.htm1. 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 DOB, a
middle name), you can submit your request again at this Web site and we will provide a new certificate
for that query.
This response reflects 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.
https://www.dmdc.osd.mil/appj/scra/popreport.do 5/13/2010
Request for Military Status Page 2 of 2
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a
period of more than 30 consecutive days. In the case 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 § 502(f) for purposes of responding to a national
emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR)
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 Health
Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a
period of more than 30 consecutive days.
Coverage Under the SCRA is Broader in Some Cases
Coverage under the SCRA is broader in some cases and includes some categories of persons 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 extend SCRA
protections. Persons seeking to rely on this website certification should check 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
extend beyond the last dates of active duty.
Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights
guaranteed to Service members under the SCRA 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 ID:HV7UOPSSJF
https://www.dmdc.osd.mil/appj/scra/popreport.do 5/13/2010
EN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIV{SIGN
DISCOVER BANK
Plaintiff
vs.
PATRICK A BASOM
Defendant
To:
PATRICK A BASOM
103 N 21ST ST
CAMP HILL, PA 17011 ,
Date of Notice:
Case No. 10-142 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 7HE COURT YOUR DEFENSES OR OBJECTIONS
TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THlS
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
FEEOI~~NO-FEE: .__ _ ---_.......~_---....___~__.-__ ...._..._-----....____~--.--___.__._.._--.--__.-.___~..-_._._.________ ........_ .__
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA. 17013
{717) 249-3166
WELTMAN, WERG & REIS CO., L.P.A.
F-
Y
Matthew Urban
P.A.1.D.# 90963
WELTMAN, WEINBERG &REIS CO., L.P.A.
436 Seventh Avenue, 1400 Koppers Building
Pittsburgh, PA 15219
Phone; (412) 434-7955
8055510 A PIT T4S
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 10-1462 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s)
From PATRICK A. BASOM AT 103 N. 21sT STREET, 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 CITIZENS BANK OF PA AT 2 WEST MAIN STREET, MECHANICSBURG, PA 17055
GARNISHEE(S) as follows:
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 $7,032.93 L.L.$.50
Interest 300.00
Atty's Comm % Due Prothy $2.00
Atty Paid $174.50 Other Costs
Plaintiff Paid
Daw 2/18/11
David D. ell, Prothonot
deal) By:
Deputy
REQUEST11•IG PARTY:
Name MATTHEW D. URBAN, ESQUIRE
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. 90963
4
2Q 11 FES 18 AM 10:
PENN'SYL.V!-,.;`liA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
iy?,,2,
Plaintiff No. 10-+40--CIVIL TERM
vs. PRAECIPE FOR WRIT OF EXECUTION
(BANK ATTACHMENT ONLY)
PATRICK A BASOM
Defendant
CITIZENS BANK OF PA,
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#8055510
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND CO-
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
PATRICK A BASOM
Defendant
CITIZENS BANK OF PA,
Garnishee
TO THE PROTHONOTARY:
Civil Action No. 10-142-
PRAECIPE FOR WRIT OF EXECUTION
Kindly issue a Writ of Execution in the above matter...
1. directed to the Sheriff of CUMBERLAND County:
2. against PATRICK A BASOM, 103 N. 21" St, Camp Hill, PA 17011, Defendant
3. against CITIZENS BANK OF PA, 2 West Main Street, Mechanicsburg, PA 17055, Garnishee
4. Judgment Amount $ 7,047.93
Less payments of $ (15.00)
Interest $ 300.00
Costs $
SUBTOTAL: $ 7,332.93
Costs (to be added by Prothonotary): $
WELTMAN, WEINBERG & REIS CO., L.P.A.
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
61C/7 G/ 3 1-/ 5s
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 o _' }
Phone: 412.434.795 5 ° --' - _....
Fax: 412.434.7959 zw -?v r`` =
File # 8055510
-<> X- C
r -a s
DISCOVER BANK p a
"
Cumberland County
Court of Common Pleas
vs.
?y a
PATRICK A BASOM
NO. 10-+4-2, CIVIL TERM
and
CITZENS BANK OF PA
Garnishee(s)
PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION
TO THE PROTHONOTARY:
Kindly marked the above matter discontinued and ended as to Garnishee(s), CITZENS
BANK OF PA, only.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By
Sworn to and subscribed
Before me the day of March, 2011
NOTARY PUBLIC
COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
Sheila G. Bevan, Notary Public
Ross Twp., Allegheny County
My Commission Expires Nov. IS, 2014
MEMBER, PENNSYLVANIA ASSOCIATION OF NOTARIES
Q,M} '%?" M ? d Ce*L
r?k+j- Si1-770,?j O
V*o1S7 Ya ?
IN THE COUE. f OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
IL44a
vs. Civil Action No. 10-teCIVIL TERM
PATRICK A BASOM i JO 3 elk
Deferaant(s)
FULTON BANK 133q gf c Iselcl 1,e 10 d ? C?I+Q ?'<< < p? 1???
Garni,hee(s)
PRAECiPE FOR WRIT OF EXLCUTION
TO THE PRC FHONOTARY:
Ki,).ily issue a Writ of Execution in the above r,httei
1. directed to the Sheriff of CUMBERLAND County:
2. against P''- BRICK A BASOM , Defendant
3. against FULTON BANK, , , Garnishee
4. Jud«rnent Amount
Les,-. Payments/credits received
l nter•. st
Costs
SUBTOTAL:
Coas (to t., added by Prot.ionotar, ):
So F
q P. co it
14, oc tt u
4 M
Ci • W
r~` CM -
C-)
CZ)
-
.,.
-
.
$7,047.93
$15.00 ,-103a.g3
$592.03 ,
$7,624.96
R ELTMAN, W EINBERG & REIS CO., L.P.A.
B `
Matthew D. Urban, Esquire
PA I.D. #90963
WELTMAN, WLINBERG & REIS CO., L.P.A.
1400 Koppers E-tilding
436 `seventh AvL-:ue
Pittsburgh, PA 15219
(412)434-7955
Ck? ?? 8?? s a
WWR No. 3055510
Wr ?" cat ? ???
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 10-1462 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s)
From PATRICK A. BASOM, 103 NORTH 21sT STREET, 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:
FULTON BANK, 3344 TRINDLE ROAD, CAMP HILL, PA 17011
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$7,032.93
Interest $592.03
Atty's Comm %
Atty Paid S. I ?0.00
Plaintiff Paid
Date: OCTOBER 26, 2011
(Seal)
REQUESTING PARTY:
Name MATTHEW D. URBAN, ESQUIRE
L.L.
Due Prothy $2.00
Other Costs
David D. Buell, Prothonotary}
B /,
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. 90963
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
?Q???n ?t +?tul2Urrf???
09'M£ ? SHERIFF
P Of /0: 06
',,UPE?RLA?p ?
NSYtVgfif? T
Discover Bank
Case Number
vs.
Patrick A. Basom 2010-1462
SHERIFF'S RETURN OF SERVICE
10/28/2011 01:27 PM - Shawn Gutshall, Deputy, who being duly sworn according to law, attached as herein
commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands,
possession, or control of the within named garnishee, Fulton Bank at 3344 Trindle Road, Camp Hill
Borough, Camp Hill, PA 17011, Cumberland County, by handing to Lauren Green, Head 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 November 1, 2011 to Patrick Basom at 103
N. 21st Street, Camp Hill, PA 17011.
11/17/2011 Ronny R Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is
returned STAYED, per request from plaintiffs attorney.
SHERIFF COST: $96.33 SO ANSWERS,
November 17, 2011 RON R ANDERSON, SHERIFF
;c Gounty5uite Sheriff. Teleosoft 1i
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson ?,,^ lt ffi,
Sheriff Q IC
j S
Jody S Smith
QIJ?I??Q
Chief Deputy-
t
Richard W Stewart
Solicitor OFFICE OF =RIFE EWS,, NO co 06
Y4 VA &tV rY
Discover Bank
vs. Case Number
.
Patrick A. Basom 2010-1462
SHERIFF'S RETURN OF SERVICE
03/02/2011 12:45 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on March 2,
2011 at 1241 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies
of the within named defendant, to wit: Patrick A. Basom, in the hands, possession, or control of the within
named garnishee, Citizens Bank, 2 West Main Street, Mechanicsburg, PA 17055, Cumberland County,
Pennsylvania, by handing to Madeline Cross, Senior 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 March 3, 2011 to Patrick A. Basom at 103 N
21st Street, Camp Hill, PA 17011.
11/17/2011 Ronny R Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is
returned STAYED, per request from plaintiffs attorney,
SHERIFF COST: $81.09 SO ANSWERS,
November 17, 2011 RON R ANDERSON, SHERIFF
(6 Cour:iySuile Sherd. Teleosoft, In",