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HomeMy WebLinkAbout10-19751k - O AFS}, ZOl0 Mt,R 19 pt, 1: 0, C. t 'M1 I? l y z IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: l0 - lqqS Civil lerwk VS. COMPLAINT IN CIVIL ACTION VICKIE R LEWIS 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 08099587 C A Pit KMJ O *Qol. oc pA A-rN Cv-* 44 350 A P.7'*a'sl 10 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No VICKIE R LEWIS 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 14AY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO PEE. 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: VICKIE R LEWIS 206 GLENN RD CAMP HILL, PA 17011 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX3159 . 4. Defendant made use of said credit card and has a current balance due of $14991.59 , 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 26.240. per annum on the unpaid balance from January 09, 2010 . A copy of Plaintiff's Statement is attached hereto, marked as Exhibit 11111 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 , VI:CKIE R LEWIS individually , in the amount of $14991.59 with interest at the rate of 26.240% per annum from January 09, 2010 plus attorneys' fees of $125.00 , and costs. fames u) WELTMAN, 436 Seve Pittsbu (412) 4 FAX: 4 080995 This law firm is a debt collector attemp our client and any information obtained arm ro t,42524 EINBERG & REIS CO., L.P.A. th Avenue, Suite 1400 h, PA 15219 -7955 338-7130 C A Pit KMJ to collect this debt for be used for that purpose. DISCnVER $14,991.59tl CARD 15 SDSN6AOt 0003807 VICKIE LEWIS 206 GLENN RD CAMP HILL PA 17011-1133 rvummum ruymeni we I Mccuum rvuntaer enaing in .7 r a7 $14,991.59 _ Enter Amount Enclosed Below Payment Due Date $ January 10, 2010 Please make check payable to Discover Card. Minimum payment due includes a past due amount of $2,756.00. Address, e-moil 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 same day. Visit Discover.com/payments today. PO BOX 6103 IIIkrrllrIIIIIIIrlrlrrlrrll CAROL STREAM IL 60197-6103 11111111 11111111111111111 111111111111111111 111 1111111111111111 000001986458275328553149915900000001499159 Discover More Card Account Summary Closing Date: December 15, 2009 page 1 of 1 Account number ending in 3159 Payment Due Date January 10, 2010 Minimum Payment Due $14,991.59 Credit Limit $12,500.00 Credit Available $0.00 Cash Credit Limit $0.00 Cash Credit Available $0.00 Previous Balance $14,991.59 Payments And Credits 0.00 Purchases + 0.00 Cash Advances + 0.00 Balance Transfers + 0.00 Finance Charges + 0.00 New Balance = $14,991.59 Cashback Bonuse Opening Cashback Bonus Balance $ 0.00 New Cashback Bonus This Period + 0.00 Cashback Bonus Balance $ 0.00 Cashback Bonus® Anniversary Month: December How Can We Help You? P 1. Visit Discover.com to pay your bill For no cost, view our latest Account information, earn and redeem rewards and more It's your choice - 3 ways to help 2. Call 1-800-DISCOVER (347-2683) for fast, easy self-service Please have your Discover Card available. options or to speak with a Customer Service Account Manager For TDD (assistance for hearing impaired) see reverse side 3. Write us at Discover Card, PO Box 30943, Salt Lake City, UT 8,4130 Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence. Information For You Your Account is overlimit. While we are permitted under the Cardmember Agreement to charge you an Overlimit Fee, we have chosen not to do so at this time. We reserve the right to do so if, as of the close of a billing period, your outstanding Account balance exceeds your Account credit limit. See the Overlimit Fee section of the Cardmember Agreement for details. EXHIBIT Finance Charge Summary Average Daily Nominal Transaction ANNUAL -ANNUAL Periodic Fee Daily Periodic Balances Rates PERCENTAGE PERCENTAGE FINANCE FINANCE RATES RATES CHARGES CHARGES current billing period: 15 days Purchases $0 0.07189% 26.24% V 26.24% $0 $0 Cash Advances $0 0.08216% 29.99% V 29.99% $0 $0 The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above Important Information. If there is more than one page to this billing statement, see the back of each page for additional important information. See your Cardmember Agreement. Your Cardmember Agreement contains all the terms of your Account o Lost or stolen cards. Report immediately! Call 1-800-347-2583. Z Milk? Rlohts Summary. In Case of Errors or Questions About Your Bill: If You think Your bill is wrong or if You need more information about a o trans ctioh on your bill, write to us on a separate sheet of DDappeer at Discover Card; PO Box 30421 Sali.Lake City. UT 84130-0421 as soon as ossible. We must hear from you no later than 50 days after We sent you the first bill on which the error or problem appeared. Vou can telephone o ?is but doing so will not preserve ur rights. In your letter, give us the following information: w • Your rating and Account numbeyor w • The dollar amount of the suspected error o • Describe the error and explalh, if you can, why you believe there 9s an error. If you need more Information, describe the item you are unsure N Youudo not have to av an amount in question while we are investigatin ,but u are still oblig?sled to the arts of your bill that are not in v question. While we PnVestigYate your question, we cannot report you as deltnquei t or take any action to cgag, t the amount you question. S and ecial Rule for Credit Card Purchases: If you have a problem with the quality of Roods or services that yvoour urchased with a credit card, vopu have tried in good faith to correct the problem with the merchant ou ma not ifave to paV the remaining amount due on the goods or services. You have this protection only when the purchase price was more than 50 anythe purchase vYas made in yo0r home state or within 100 miles of Your mailin address. (if we own or o erate the merchant or If we mated you the advertisement for the goods or services, all purchases are covered fegardless the amount or location of purchase) P nts. Send onl r avm?nt and th to ortion of this statement in the envela ?ovided. Do n ?t send cash. g? sendin ur check as de cs r bed above, vovYteoRze us to use ineforr?ia ion on your check to make an electropngcpfund transfer from your acco0nt at th% rinancial institution Indicated on your check or Mc rocess the pa inent as a check transaction. If payment is processed as an electronic fund transfer, the transfer will be for the amount of the k. When we uyse information from yvoour check to make an electronic fund transfer funds ma , 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 nancial institution. The rocessin of your a ent may be delayed if u send cash, correspondence or other items with your vment IV n send the payment to an other addres? or fi yo use an envelope other tharf the one provided. Payments received on or after 1 I M at ur proc sin facility Monde Y , thi?ougggh Friday or on a weekend or bank iolidaV will be posted o your Account as of the next business day. If you have misplaced oUr envelope send your payment to Discover Bank, PO Box 6,03 Carol, Stream, IL 60197-6103. Please allow 7-10 days far delivery. If your payment is returned urn aI , we r erve then ht to resubmit it as an electronic debit You can Gay?Yyoour minimum payment or a greater amount over the telephone, and you can set uD automatic DDaYYments. Cali us at 1-800-347-2603. You will need this statement acid your bank account information. You must ensure that sufficient funds are avaliabie In ur bank account and all transactions must compplyv 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 electi "c signature, your will be a re?in9 to this authorization to allow Os and your bank to deduct each gayymm?nt you authorize from our bank account and [o Initiate debit or cre?it entries to Your bank account as applicable, to correct an error in th process ng of such avm nt You must tell us the amount of each pavr ant or your can select an amount suc as the Minimum Pa ment Due or the New Balance on epoch statement You can cancel a pa ment; however we must receive notice at least three business days in ad?rance of th e scheduled payment You ma? notify us by phone at 1-800-347y 3 orY y mail at the address listed in the revious paragraph. IT vour pa ants var In amount we will tell 0 oach mdnthlV statement when ur pa ant will be made and how much ?t will be. Your auto ma tic p a m t may be less than Yndid n eated on the moTtthly statement based do credits or payments applied during the billing cycle. Credit Reporting. We may report information about t account to credit bureaus. Late oaYments, missed payments, or other defaults on your account rife be reflected iny? ur credit report We nbrmall report the status and pavmet t History of your Account to credit re ortinQ a envies each month. If v9i believe that Pueport is inaccurate or incori oletPeoplease write us at the following address: Discover Card, PO Bx 1536,gYVilmington. DE 19850=5316. Please indtude your name, address, home telephone number and Account numtfer. Grace Period on Purchases (at least 25 days). We begin to im ose Periodic Finance Charges on all transactions from the Transaction Date for the transaction as shown on Your billin statement, unless a transaction is posted to ur Account after the close of the billin period In which it occurs, in which case we begin fo impose ?enodic Finance Char es on that transaction ftom the first day of the billing period In Which it is posted to your Account We continul to impose Periodic Finance Charge until the date our pa your entire Nm Balance, by Tnakin payments or receiving credits. However, if You paid the New Balance on your previous billing statement sYy tlMvment Due Date shown on that biliri statement and you r the New Balance by the Payment Due Date on yvoour current billing statement we will nDt Impse Periodic Finance Chaarrges Bala c prams erssor cashs purchases first appearing on the current bining statement We call his the "grace period." There Is no race pera advances. Minimum Finance Charge. We will charge you a minimum FINANCE CHARGE of $.50 for any billing period in which Periodic Finance Charges of less than $.50 would otherwise be impose . Annual Fee. If yyoour Account has an annual fee, it will be billed at the be inning of each anniversary yyeear your Account is open. The amount of the fee aDDears bn the statement when the fee is billed. The annual fee i not refundable unless you Notify us that You wish to close your Account within Mays of the mailing or delivery date of the statement on which the fee is billed. You will receive this refund even if you use your Card during that period. Periodic Finance Charges. We sort your transactions Into groups of purchases, cash advances and balance transfers and then further sort the transactions within eacls rou by their Annual Percentage Rate. For Ample, purchases sublI'ect to a rate and purchases sub ect to a standard rate would be so ar?te groups. We refer to there roups as transaction categories. At the enof each billing period, we computi balances and Periodic Finance Charges for each day of the billing period for each transaction Category. We use the following equation to compute Periodic Finance Charges for each transaction category (Average Daily Balance) times (days in billing period) times (Daily Periodic Rate). ((You may refer to the finance charge summa N on your billing statement for these amounts.) Then we add uD the Periodic Finance Charges for each transaction category_ to get the total Periodic Finance Charge for your.Account The Average Daily Balance is shown as zero if, because of the grace new transactions) method of cSlc6latin9 the balance upon which we Imp, se Periodic Finance for each transaction categoiV addirfq up all the dally balances in a billingnperiod for a e number of days in the bitllri9g?eriod. vve commute the daily balance for ead transaction category previous day's daily_balance: ttansactions.with a Transaction Date of that day,as,shown on your ince for th9 first da of the-1:1111-1 frig ppeerlod, we corSfider the on the last day of ur previous 6iilin eriod. gory with the exctiorf of Cash AdvaTtCe Transaction Fee aTrd Ealance TransTeQr Transaction Fee Finance Charges which move the unpaid balance of the balance expires, we ^hase transaction cateoorv. However. if the special rate has 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# 8099587 Vickie R. Lewis 159 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson ~~'' 1`~ Sheriff ~~~ Jody S Smith ~ tf~ Chief Deputy ; , ~~~f3 hA~ ~~ ~• Edward L Schorpp , ..,• ~ .. Solicitor ~~` `~'~~ ~~~ Discover Bank vs. Vickie R. Lewis Case Number 2010-1975 SHERIFF'S RETURN OF SERVICE 03/22/2010 08:27 PM -Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on March 22, 2010 at 2025 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Vickie R. Lewis, by making known unto herself personally, at 206 Glenn Road, 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. SHERIFF COST: $41.50 March 23, 2010 ~ri~~ 7'~ TIM~BLAC~i ,, DEPUTY SO ANSWERS, ~/ RON R ANDERSON, SHERIFF ,. Cri to Sr t (eieoa ^T Inc. E LU~Irit~,+ [.~ ~ ~ t :'vim Cv, - DISCOVER BANK IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Plaintiff No: 10-1975 CIVIL TERM vs. VICKIE R LEWIS 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 08099587 C A Pit KMJ Judgment Amount $16375.64 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 10-1975 CIVIL TERM VICKIE R LEWIS PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONTARY: Kindly enter Judgment against the Defendant VICKIE R LEWIS above named, in the default of an Answer, in .the amount of $16375.64 computed as follows: Amount claimed in Complaint $14991.59 Less payments / adjustments made $0.00 Interest on the remaining principal balance of $14991.59 from January 09, 2010 to May 06, 2010 @ the interest rate of 26.240a per annum $1259.05 Attorney's fees $125.00 TOTAL $16375.64 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. ,42524 08099587/ C ~A Pit KMJ 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 endant is VICKIE R LEWIS 206 GLENN RD CAMP HILL, PA 17011 ~I~.oo Pp ~`~'~f CK,# ~s8~9~D 1~o-hee, ~lou~.c~ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. VICKIE R LEWIS Civil Action No. 10-1975 CIVIL TERM NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the f~llowing Order of Judgment was entered. against you on 5/~I~b (xx) Assumpsit Judgment in the amount of $16375.64 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 ~ ~~_~ ~Yl~ ~ VICKIE R LEWIS 206 GLENN RD 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. 10-1975 CIVIL TERM VICKIE R LEWIS 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 VICKIE R LEWIS 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. VICKIE R LEWIS 206 GLENN RD 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 08:36:24 Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agenc LEWIS VICKIE 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,defenselnk.mil/fad/his/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:FL3VTU41VH https://www.dmdc.osd.mil/appj/scra/popreport.do 5/13/2010 t r IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. VICKIE R LEWIS Defendant Case Na. 10-1975 CIVIL TERM IMPORTANT NOTICE TO. VICKIE R LEWIS 206 GLENN RD CAMP HILL, PA 17011 Date of Notice: 0~~ ~ ~ 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 OF 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 HAVE 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 WITF1 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 (717) 249-3166 WELTMAN, Vy.Et11fBERG &REIS CO., L.P.A. ~y: Matthew Urban P.A.I.D.# 90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 8099587 A PIT T4S IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. VICKIE R LEWIS l? «t Q? ?-10`? At+a CICAY1 ?CL Defendant PSECU, DY 9k; nsbg, P? IZaS? Oc d (vtoar? ?k Garnishee Civil Action No. 10-1975 CIVIL TERM C7 N C) -u rn o -+o > ° M ? V D PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: 2. against VICKIE R LEWIS, Defendant 3. against PSECU, Garnishee 4. Judgment Amount Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): a'd. 50 ?D a? s Lf 1 So CO q'j.ao %,% %%4.00 u $ 16375.64 $ 629.90 $ 17005.54 WELTMAN, WEINBERG & REIS CO., L.P.A. By: __?%?G' William T Molczan, E re PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 -txe Co a.w so LL Ck -50blo729 T?>50-ec? Q 14 -7 1P IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. VICKIE R LEWIS Defendant PSECU, Garnishee, No. 10-1975 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: c7 C -9 3 -.. rra -w? vo N 0 J 0 William T Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#08099587 C) -i x-n rnr:.. -Orn o° qo =-n o-n z c) oM D WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-1975 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s) From VICKIE R LEWIS, 206 Glenn Road, 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: PSECU, 1871 Old Main Drive, Shippensburg, PA 17257 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 $:14 J 31S. 64 Interest $629.90 L.L. $.50 Atty's Comm % Atty Paid $174.50 Plaintiff Paid Date: 1/18/11 (Seal) REQUESTING PARTY: Name -'WILLIAM T. MOLCZAN, ESQUIRE Due Prothy $2.00 Other Costs Da 'Zuell, Prot notary By: Deputy Address: WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 47437 WELTMAN, WEINBERG & REIS CO., L.P.A. BY: James C Warmbrodt, Esquire I.D. No.42524 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 8099587 DISCOVER BANK vs. VICKIE R LEWIS and PSECU Garnishee(s) Attorney for Plaintiff(s) CUMBERLAND County Court of Common Pleas NO. 10-1975 CIVIL TERM PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: r" Kindly marked the above matter discontinued and ended as to Garnishee(s), PSECU, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By Sworn to and subscribed Before me the day of February, 2011 OTARY PUBLIC Jam C armbrodt, Esquire Attv for Plaintiff Notarial Seal - Sheila G. Bevan, Notary Public Roes Twp,, Allegheny County My Commission Wm Nov. 15, 2014 4461 Whipi bu?e ? 776 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-1975 Civil CIVIL ACTION - LAW TO THE SHERIFF OF DAUPHIN COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s) From VICKIE R. LEWIS - 206 Glenn Dr., 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: PSECU - I Credit Union Pl., Harrisburg, PA 17110 PNC BANK - 2 N. Second St., Harrisburg, PA 17101 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 $16,375.64 Interest $1,620.52 Atty's Comm % Arty Paid $209.00 Plaintiff Paid Date: 1/19/12 (Seal) L.L. Due Prothy $2.25 Other Costs Deputy REQUESTING PARTY: Name WILLIAM T. MOLCZAN, 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. 47437 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 10-1975 CIVIL TERM VS. PRAECII'E FOR WRIT OF EXECUTION AND ENTER IT IN THE JUDGMENT INDEX (BANK ATTACHMENT ONLY) VICKIE R LEWIS Defendant PSECU AND PNC BANK, Garnishee, FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#08099587 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. /1 Civi `?tion No. 10-1975 CIVIL TERM VICKIE R LEWIS - 20? 610o n br' a/?? b9 /-70 Defendant ?'S vq, AW /?7// O _> / Cre d, f Ur i oA P/., #di? 6 PSECU AND PNC BANK, _ ,2 Selo/Ic+? S7? Na??1 s 6? P? /7/o/ Garnishee , , ., PRAECIPE TO INDEX WRIT OF EXECUTION - -? AND ENTER IT IN THE JUDGMENT INDEX M CD TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... ?; ` 1. directed to the Sheriff of Dauphin County: rte- 2. against Vickie R Lewis, Defendant 3. against PSECU AND PNC BANK, Garnishee' -- 4. and enter this writ in the judgment index w= ?? (a) against Vickie R Lewis, defendant, and (b) against PSECU AND PNC BANK, as garnishee, as a lis pendens against real property of the defendant in the name of garnishee as follows: Any and/or all personal prope belonging to the defendant(s) in possession of the amishee(s) 5. Judgment Amount Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): $ 16375.64 $ 1620.52 $ 17996.16 0 2q. 00 f7? 60 c BP `l2. oo I c?. oo ll 8• do r/ aoq oo pd #0?. A 5 du e Co C'?103/92°? pyt.26'7 s?Pc? WELTMAN, INB/ERG & REIS CO., L.P.A. By: "J, William 'r Molczhn, Er PA I.D. 447437 WELTMAN, WEINBERG & REIS CO., L.P.A 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WELTMAN, WEINBERG & REIS CO., L.P.A. BY: James C Warmbrodt, Esquire I.D. No.42524 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 8099587 DISCOVER BANK vs. VICKIE R LEWIS and PNC BANK Garnishee(s) Attorney for Plaintiff(s) L ' ? 2 MAR _ 5 AN I I : +} UMISE ELAND COUNT ;` PENNSYLVANIA _ Cumberland County Court of Common Pleas NO. 10-1975 CIVIL TERM PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter discontinued and ended as to Garnishee(s), PNC BANK, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By I hereby certify that the foregoing is a true and correct This statement is made subject to the penalties of 18 C Warmbrodt, Esquire ey for Plaintiff the above case. relating to unsworn falsifications to authorities. a}?R.s'a?d4 163??.?c;J , WELTMAN, WEINBERG & REIS CO., L.P.A. BY: Matthew D. Urban, Esquire Attorney for Plaintiff(s) I.D. No.90963 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 8099587 DISCOVER BANK vs. VICKIE R LEWIS and PSECU Garnishee(s) CUMBERLAND County Court of Common Pleas NO. 10-1975 CIVIL TERM PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: - n x, C-) Kindly marked the above matter discontinued and ended as to Garnishee(s), PSECU, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By Matthew D. Urban, Esquire Attorney for Plaintiff WELTMAN, WEINBERG & REIS CO., L.P.A. ?? ?t?R BY: Sarah E. Ehasz, Esquire Attorney for Plaintiff(s) -4 AH 1 J : 46 I.D. No.86469 n{???{? 436 Seventh Avenue, Suite 1400 PENNSYLVANIA ND COUNTY Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 8099587 DISCOVER BANK Plaintiff VS. VICKIE R LEWIS Defendant(s) CUMBERLAND County Court of Common Pleas NO. 10-1975 CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT TO THE PROTHONOTARY: Please kindly Satisfy the Judgment of the above-captioned matter upon the records of the Court and mark the cost paid. WELTMAN, By Sworn to and ed Before mew day o 2012 I N WEINBERG & REIS CO., L.P.A. 1',' 4/ Sarah E. Ehasz, Esquire Attorney for Plaintiff COMMONWEALTH OF PENNSYLVANIA Nourlal Seal Wendy L Gault, Notary public L City a pittsburgh, ? hjvjj 15, et)t, Lc 2Q14 My COMMladon Member, NOV" ! NiIwelOn of Nots+rl4s ?q.so ? LAL L/ PAI-_ a??H