HomeMy WebLinkAbout10-1824FILED
{ Yte,. star E,"?' ,1?( r •\?'?'T ?.? 1
03
2ol0 12 ph 3:
Cvcv ??_ ,.??? fY
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff No: ?b - ISa4 aw 4 -Fet-VA
VS.
COMPLAINT IN CIVIL ACTION
JEREMY SHADE
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
08100626 C A Pit KMJ
Q?)
f qa. co Pb Arty
cjcw 44 a096
P"#assSIa
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No
JEREMY SHADE
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:
JEREMY SHADE
100 MILL-RD # 1
NEWVILLE, PA 17241
3. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXX1257
4. Defendant made use of said credit card and has a current balance
due of $5458.23 , as of January 09, 2010
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
24.990% per annum on the unpaid balance from January 09, 2010 . A copy
of Plaintiff's Statement is attached hereto, marked as Exhibit "1" 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 , JEREMY SHADE individually , in the amount of
$5458.23 with interest at the rate of 24.9906 per annum from January
09, 2010 plus attorneys' fees of $125.00 , and costs.
This law firm is a debt collector at
our client and any information obtai
James A. Wa ro t,42524
WP?O WEINBERG & REIS CO., L.P.A.
4nth Avenue, Suite 1400
Pgh, PA 15219
(4-7955
F -338-7130
0C A Pit KMJ
to collect this debt for
be used for that purpose.
5 458.23ce
DISUNER '$,qew
' CARD
15 SDSN6A01 0004847
JEREMY SHADE
100 MILL RD # 1
NEWVILLE PA 17241-9404
rvummum raymenr vue
$5,458.23 J r,ccoum rvumoer enamg in i Aar
Enter Amount Enclosed Below
Payment Due Date $ 1-=
January 14, 2010 Please make check payable to Discover Card.
Minimumpa ment due includes a past due
amount of $996.00.
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 Hill Rill loll
CAROL STREAM IL 60197-6103
IrILJIrr?r?rIIIJ?rI?rJJI?rr??IIII?r?r?ILIL?rr?llrrl?rll
000001986618011284408054582300000000545823
Discover More Card Account Summary
Closing Date: December 15, 2009 page 1 of 1
Account number ending in 1257 Previous Balance $5,458.23
Payment Due Date January 14, 2010 Payments And Credits 0.00
Minimum Payment Due $5,458.23 Purchases + 0.00
Credit Limit $5,000.00 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 = $5,458.23
Cashback Bonus® Opening Cashback Bonus Balance $ 0.00
New Cashback Bonus This Period + 0.00
Cashback Bonus Balance $ 0.00
Cashback Bonus® Anniversary
Month: June
How Can We Help You?
It's your choice - 3 ways to help
Please have your Discover Card available.
For TDD (assistance For hearing impaired) see reverse side
1. Visit Discover.com to pay your 601 for no cost, view our
latest Account information, earn and redeem rewards and more
2. Call 1-800-DISCOVER (347-2683) for fast, easy self-service
options or to speak with a Customer Service Account Manager
3. Write us at Discover Card, PO Box 30943,
Salt Lake City, UT 8,4130
EXH?R
Finance Charge Summary
Nominal Transaction
Average Daily ANNUAL -ANNUAL Periodic Fee
Daily Periodic PERCENTAGE PERCENTAGE FINANCE FINANCE
Balance s Rates RATES RATES CHARGES CHARGES
current billing period: 15 days
Purchases $0 0.06847% 24.99% F 24.99% $0 $0
'Cash Advances $0 0.06847% 24.99% F 24.99% $0 $0
The rates that apply to your Account are either fixed (F) or they may vary (V) 03 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.
B'Mng Rights Summary. In Case of Errors or Questions About Your Bill: If you think our bill is wron , 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 Trom you no later than 6 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 may not have to pay the remaining amount due on the ds 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 wlgoohin 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 other address or if you use an envelope other than the one provided. Payments received on or after 1 PIM 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. our bank a count and all
You will needd this statement and your bank account information. You must ensure that sufficient funds are available in y
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 tiate 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 Our or the New Balance on
each statement. You can cancel a pa merit however we must receive notice at least three business days in advance of the scheduled payment. You
may notify us by phone at 1.800.347 683 or by mail at address listed in the previous Paraggraph If your payments may vary in amount we will tell
yoy 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 Mores Card, PO Box 15316.
Wilmington DE 19850-5316. Please include your name, address, home telephone number and Account number.
Periodic Finance Chases Except as provided below, we will impose Periodic Finance Charges on purchases, cash advances and balance transfers
beginning with the date the transaction occurs until the date of repayment and on Old Balances until the date of repayment Old Balances are
comprised of either purchases and cash advances made on or prior to the last day of your billing period ending during February 1993 or Reserve
on new purchases if you pay the New Balance shown on the billing statement on which the
he Payments and Credits on that statement equal or exceed your Previous Balance. We call
riod on balance transfers or cash advances. Periodic Finance Charges are imposed on new
balance transfers and cash adv
Periodic Finance Charges are
New Balance. However, if you
on this statement equal or exi
on this stater
alance shown
a tra
the
Cement We comput
isaction cafeggofyy and
each day by TirsT add
ages accrued on the
isaction category on
.he New Balance Shown on
the Previous Balance we
r Account was closed as o
date
on
of your entire
Credits shown
iurchases first
on this Statement by the Payment Due Date and the Payments and Credits on 11`115 statement equal or exceea your rrevious
will receive a billing statement next month that includes Periodic Finance Charges imposed until the date of repayment
:finance Charges, each day for purchases, cash advances, balance transfers and Old Balances (which we refer to as transaction
following equation: Average Daily Balance x number of days in the billing period x Daily Periodic Rate. (Refer to the finance
front of your statement for these amounts.) Then we add all the Periodic Finance Charges for each transaction category to
nance Charges for your Account The Average Dairy Balance is shown as 0 if no Periodic Finance Charges apply to the
cle?adve rage daily balance (including new transactions) method of calculating the balance upon which we impose Periodic
neans.if you did not pay the New Balance shown on the billing statement you received during the previous billing period by
ear on this billing statement, unless we already imposed Periodic Finance Charges on the purchases on your previous billing
e the average daily balance for each transaction category by adding up all the daily balances in a billing period for a
dividing the total b the number of days in the billing cycle. We compute the daily balance for each transaction category
ing the following to the previous days daily balance: transactions made that day, fees charged that day and Periodic Finance
previous days daily balance; and by then subtracting any credits and payments that are applied against the balance of the
that day. In calculating the daily balance for the previous billing period, we consider the previous days daily balance" to
have been 0 on he first day of the billing eriod
Old Balances are excluded from the balapnce of the purchase and cash advance transaction categories. Special rate balance transfers and Balance
Transfer Transaction Fee Finance Charges are included in the daily balance transfer transaction category. Balance transfers that were subject to an
initial spec ial rate that has been terminated due to a late payment or because you exceeded your Account credit limit are also included in the
cate "'a' until the initial special rate otherwise would have expired. In calculating the daily balance of the balance transfer transaction category on
the lust day of the billing period, we subtract the unpaid balance of those Balance Transfer Transaction Fee Finance Charges and balance transfers
that become purchase rate balance transfers on that Say and we add that unpaid balance to the balance of the purchase transaction category. All fees charged to your Account are added to the purchase transaction category with the exception of Cash Advance Transaction Fee Finance
Charges which are added to the cash advance transaction category and Balance Transfer Transaction Fee Finance Charges which are added to the
balance transfer transaction category. If a transaction made in a previous billing period is itemized on this statement, we consider the transaction
rialo in hr the first rtav of the rurrent hiilinn nerinrt when we ralrularr vniii Perinair finance Charnec
rn
0
rn
Z
D
0
00
m
A
N
X
v
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.
W WR# 8100626
Jeremy Shade
1257
~;'
' T c -.._
~ - ~~
2~1~~~;'~` ~~~ PIS l~ 24
DISCOVER BANK
Plaintiff
vs.
JEREMY SHADE
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
No: 10-1824 CIVIL TERM
PRAECIPE FOR DEFAULT JUDGMENT
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
James C. Warmbrodt,42524
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434-7955
FAX: 412-338-7130
08100626 C A Pit DIP
Judgment Amount $6059.84
~I~.OO IAA ~~
CK.~ ~F5989~~
'~~" a~ a s8lo
i~rkea, ~
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
JEREMY SHADE
Civil Action No. 10-1824 CIVIL TERM
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the ollowing Order of Judgment
was entered against you on ~~ ~p
(xx) Assumpsit Judgment in the amount of $6059.84 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. ~
PROTHO OR DEP',
JEREMY SHADE
10 0 MILL RD ## 1
NEWVILLE, PA 17241
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. 10-1824 CIVIL TERM
JEREMY SHADE
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONTARY:
Kindly enter Judgment against the Defendant JEREMY SHADE above named, in
the default of an Answer, in the amount of $6059.84 computed as follows:
Amount claimed in Complaint
Less payments / adjustments made
$5458.23
$o.oo
Interest on the remaining principal balance of
$5458.23 from January 09, 2010 to May 17, 2010
@ the interest rate of 24.9900 per annum $476.61
Attorney's fees
TOTAL
$125.00
$6059.84
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. r roc~.t, 42524
0810062 CAA Pit DIP
Plaintiff's address is: t
c/o WELTMAN, WEINBERG & REIS CO., L.P.A.,
436 Seventh Avenue, Suite 1400 Pittsbur h PA 15219
And that the last known address of the(~°efendant is
JEREMY SHADE
100 MILL RD ## 1
NEWVILLE, PA 17241
IN THE Ct)URT QF COMMON RLEAS CUMBERLAND COUNTY, RENNSYLVANIA
CIVIL pIVISICQN
CtIS~E?VER RANK
Plaintiff
v s.
JEREMY SHADE
Defendant
Caae NQ, 10-1828 CIVIL TERM
I P FiTAN"f ~fQ,TI~
Tp:
JEREMY SHADE
100 MILL RD # 1
NEWVILLE, PA 17241 ~~1t~
Date of Notice: ~tX ~ Q __~____
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 OBJECTlON4`
TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THI,~
NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUF',
PROPERTY OR OTHER IMPORTANT RIGHTS.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT NAVE A LAWYER, GC-
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 WITF
INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCEC!
FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA. 17013
(717j 249-3166
WELTMAN,)A1~JBERG & REIS CO., L.P.A
~sy:
Matthew Urban
P,A.I.D.# 90963
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue, 1400 Koppers Building
Pittsburgh, PA 15219
Phone: (412j 434-7955
8100626 A PIT T4S
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No. 10-1824 CIVIL TERM
NON-MILITARY AFFIDAVIT
JEREMY SHADE
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 JEREMY SHADE 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.
JEREMY SHADE
100 MILL RD $# 1
NEWVILLE, PA 17241
is not in the military service. Further Affiant sayeth naught.
bequest for Military Status
Department of Defense Manpower Data Center
Military Status beport
~; Pursuant to the Service Members Civil Relief Act
fi
Page 1 of 2
May-192010 12.12;9
.. Last
Name First/Middle Begin Date Active Duty Status Active Duty End Date Service
Agency
SHADE JEREMY 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
1f00 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 l 940}.
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/faa/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 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/scrafpopreport.do 5/19/2010
Request fc~r Military Status 1'~g~ 2 ~f
A4'ore in~ormatian un "A~tive duty Status ~`
Active duty status as reported in this certificate is defined in accordance with 1p IJSC ~ 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 cal! 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 Zlnder the SCRA is Broader 1n 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:NC8SIUROVF
https://wvvw.dmdc.osd.mil/appj/scrafpopreport.do S/1 W2010
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 10-1824 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s)
From JEREMY SHADE AT 100 MILL ROAD #1 NEWVILLE, PA 17241
(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 MEMBERS 1sT FCU AT 1711 SPRING ROAD CARLISLE, PA 17013
ACNB BANK AT 37 CARLISLE ROAD NEWVILLE, PA 17241
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 $6,059.84
Interest $283.60
L.L.$.50
Atty's Comm %
Atty Paid $171.80
Plaintiff Paid
Date: 3/11A I
(Seal)
REQUESTING 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
Due Prothy $2.00
Other Costs
Deputy
Telephone: 412-434-7955
Supreme Court ID No. 90963
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff No. 10-1824 CIVIL TERM
vs. PRAECIPE FOR WRIT OF EXECUTION
(BANK ATTACHMENT ONLY)
JEREMY SHADE
Defendant(s)
MEMBERS I ST FCU
ACNB BAN K = '
Garnishee(s)
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF rte '
THIS PARTY:
Matthew D. Urban, Esquire
PA I.D. #90963
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
(/ i
?i'/ . ?
??? ?{ t b6fj Pittsburgh, PA 15219
(412) 434-7955
rr
3d ?U /
Cyr
t-r n/?' DD
/ 1
10/7/. S6 &AVk7
ok ft j5618 4a6'5'
WWR No. 8100626
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No. 10-1824 CIVIL TERM
JEREMY SHADE
Defendant(s)
MEMBERS I ST FCU
ACNB BANK
Garnishee(s)
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Kindly issue a Writ of Execution in the above matter...
I . directed to the Sheriff of CUMBERLAND County:
2. against JEREMY SHADE , Defendant
3. against MEMBERS 1 ST FCU, ACNB BANK,, Garnishee
4. Judgment Amount $ $6,059.84
Interest $ $283.60
Costs $
SUBTOTAL: $ $6,343.44
Costs (to be added by Prothonotary): $
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
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 No. 8100626
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
Discover Bank, Judgment & Writ Number
Plaintiff, 10-1824 Civil
V. Attachment Execution c
11
Proceedings -103 = -t
Jeremy Shade, rn m
Defendant, W r- r n
te x' Q
and r
-
<c: -9-
:z rz?
ACNB Bank,
Garnishee.
.,r
PROOF OF NOTICE TO DEFENDANT
COMMONWEALTH OF PENNSYLVANIA,
COUNTY OF ADAMS.
On this, the 3IS:f' day of March, 2011, before me, a Notary Public, in and for said
Commonwealth and County, the undersigned officer, personally appeared Edward G. Puhl,
Esquire, attorney for ACNB Bank, the Garnishee in the above entitled attachment execution
proceedings, who having been by me duly sworn, according to law, on his oath, does depose
and say that on March 31, 2011, he forwarded to the Defendant, Jeremy Shade, a copy of the
writ issued in said proceedings on March 28, 2011, and a copy of ACNB Bank's Answer to
Interrogatories, by mailing the same certified mail deposited at the post office in Gettysburg,
Adams County, Pennsylvania, addressed to the Defendant at the following address:
100 Mill Road #1, Newville, PA 17241.
Attached to this Proof of Notice is the certified mail receipt showing the aforesaid
mailing of the items hereinbefore mentioned.
Edward G. Puhl, Esquire
Sworn to and subscribed before me
this ,.3130- day of March, 2011.
ZA:2 [ X0, C7iLt,?tr?D
Notary Public MONWEALTH OF PENNSYLVAI
Notarial Seal
Leslie R. Grimes, Notary Public
My commission expires: Gettysburg Boro, Adams Cm*
My CorrrMssiort Bow Oct 23, 2011
Member, Pennsylvania Association of Nots
..1
ri postage $
Q'
Caddied Fee
C3
O Retum Receipt
Fee
O .
(Endorsement Requud)
°
Restricted Delivery Fee
° (Endorsement Required)
ru
sa Total Postage & Fees
°
AL USE
jr
Postmark
fl,l_l?f Here
$0.l ij
cr t o
Jeremy Shade
N orPtJtBoxtNO' 100 Mill Road #1
CHY, stab, 27p+4Newville, 13A 17241
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION - LAW
Discover Bank, No. 10-1824 Civil
Plaintiff,
vs.
Jeremy Shade, C-)
c
Defendant,
rnco
?- ?
z-q
rnr-
-VM
VS. -stn :;01=
ACNB Bank, c---n
Garnishee. y ,r',
CERTIFICATE OF SERVICE
AND NOW, this day of April, 2010, I, Edward G. Puhl, Esquire, of Puhl,
Eastman & Thrasher, attorney for Garnishee, ACNB Bank, hereby certify that I have this date
served Garnishee's Answers to Interrogatories, by mailing the original and one true copy first class
mail, postage prepaid, to Matthew D. Urban, Esquire, at the address shown below:
Weltman, Weinberg & Reis Co., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
PURL, EASTMAN & THRASHER
By:
Edward G. Puhl, Esquire
Attorney ID# 55709
Attorney for Garnishee
220 Baltimore Street
Gettysburg, PA 17325
(717) 334-2159