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HomeMy WebLinkAbout10-2126(7 T ' F' u ,?OTkRY 2010 MAR 26 P?`l 3= 19 cufk? t !i i=ENNSYLVAN A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. ELOISE G TOWNSEND Defendant No. 10 -0j102(0 aisjl(Term PRAECIPE TO TRANSFER JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Michael J. Dougherty PA I.D. # 76046 Weltman, Weinberg, & Reis, CO., L.P.A. 325 Chestnut Street, Suite 501 Philadelphia, PA 19106 215-599-1500 WWR# 07509470 :?gq.00 P 0 A77-Y 8018 1173 >Z As9 551 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. ELOISE G TOWNSEND Defendant NOTICE OF JUDGMENT OR ORDER ELOISE G TOWNSEND TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judgment was entered against you on (xx) Assumpsit Judgment in the amount of $11,220.51 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 ( ) Default ( ) Verdict ( ) Arbitration Award ELOISE G TOWNSEND 2 MARYLAND CIR. WHITEHALL,PA 18052 Prothonotary By: PROTHONOTARY (OR DEPUTY WWR# 07509470 3?oZdo?lD IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. ELOISE G TOWNSEND Defendant TO THE PROTHONOTARY: Civil Action No. PRAECIPE TO TRANSFER JUDGMENT Please file the enclosed certified transcript of the Judgment and Docket Printout. Please enter the judgment for Plaintiff, DISCOVER BANK and against Defendant, ELOISE G TOWNSEND in the amount of $11,220.51 with interest from SEPTEMBER 30, 2009 at the interest rate of 6.00% per annum transferred from the Court of Common Pleas of LEHIGH County. Date WELTMAN, WEINBEERRG & REIS CO., L.P.A. Bv: Michael J. Dougherty PA I.D. # 76046 Weltman, Weinberg, & Reis, CO., L.P.A. 325 Chestnut Street, Suite 501 Philadelphia, PA 19106 215-599-1500 WWR#07509470 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. ELOISE G TOWNSEND Defendant Civil Action No. CERTIFICATION OF ADDRESSES 1, Michael J. Dougherty, hereby certify that the name(s) and address(es) listed below are true and correct. Attorney for Plaintiff: Michael J. Dougherty Address: Weltman, Weinberg & Reis, Co., L.P.A. 325 Chestnut Street, Suite 501 Philadelphia, PA 19106 Plaintiff: DISCOVER BANK Address: 6500 NEW ALBANY ROAD NEW ALBANY, OH 43054-000 Defendant: ELOISE G TOWNSEND Address: 2 MARYLAND CIR. WHITEHALL,PA 18052 WELTMAN, WEINBERG & IS CO., L.P.A. Date: Bv: Michael J. Dougherty PA I.D. # 76046 Weltman, Weinberg, & Reis, CO., L.P.A. 325 Chestnut Street, Suite 501 Philadelphia, PA 19106 215-599-1500 WWR#07509470 IN THE COURT OF COMMON PLEAS OF LEHIGH COUNTY, PENNSYLVANIA CIVIL DIVISION Discover Bank VS File No: 2009-C-3362 Eloise G Townsend CERTIFICATION OF JUDGMENT Pursuant to applicable judgment acts,* I, the undersigned Clerk of Judicial Records of Lehigh County, Commonwealth of Pennsylvania, do hereby certify that the judgment in the above case was entered in favor of Discover Bank And against Eloise G Townsend 6500 New Albany Road New Albany, OH 43054 2 Maryland Cir Whitehall, PA 18052 On the 30th day of September, 2009, in said case in the amount of $11,220.51. IN TESTIMONY WHEREOF, I have hereunto set my hand and affixed the seal of the Court, on the 8th day of March, 2010 Andrea E. Naugle Lehigh unty C erk of di ' 1 R ords By: D y Uniform Enforcement of Foreign Judgments Act CV6 Pa.R.C.P.3002(a) 42 PA.C.S.A.4306 (rev.12/99) • F LEHIGH COUNTY PENNSYI,V IN THE COURT OF COMMON PLEAS O CIVIL DIVISION 4L \ DISCOVER BANK V. _ v File No. 2009-C-3362 °P ur- ELOISE G TOWNSEND ?,. r^ .* CA ?` G<'p g C7 PRAECIPE FOR JUDGMENT G TO THE PROTHONOTARY OF SAID COURT: N Enter Judgment in favor of Plaintiff/Defendant and against: ELOISE G TOWNSEND for want of an Answer. ® Assess damages as follows: Debt Interest from Attorney's Commission TOTAL $ 9,720.51 $ 11,220.51 ? I certify that the foregoing assessment of damages is for specified amounts alleged to be due in the complaint and is calculable as a sum certain for the complaint. ® Pursuant to Pa.R.C.P. 237 (notice of praecipe for final judgment or decree), I certify that a copy of this praecipe has been mailed to each other party who has appeared in the action or to his/her Attorney of Record. ? Pursuant to Pa.R.C.P. 237. 1, I certify that written notice of the intent to file this praecipe was mailed or delivered to the party against whom judgment is to be entered and to his/her Attorney of Record, if any, after the default occurred and at least ten days prior to the date of the filing of this praecipe and a copy of the notice is attached. DATE: Signature: Print Name: Michael J. Doughedy Attorney for Discover Bank Address: 325 Chestnut Street, Suite 501 Philadelphia. PA 19106 Telephone: (215) 599-1500 Supreme Court ID No: 76046 NOW, , 20 , JUDGMENT IS ENTERED AS ABOVE. By. (Rev,AD) wwR 7509470 Andrea E. Naugle Clerk of Courts Deputy I, Andrea E. Naugle, Clerk of Judicial Records of the Court do of Common Pleas of Lehigh County, AMOMOWn. certify that this is a true and correct copy of the orWal record filed in said Court. Andrea E. Naupla. Clerk of Judicial Records Date LMPUjY (j' a IN THE COURT OF COMMON LEAS LEHIGH COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. ELOISE G TOWNSEND Civil Action No. 2009-C-3362 PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONTARY: Kindly enter Judgment against the Defendant ELOISE G TOWNSEND named, in the default of an Answer, follows: Amount claimed in Complaint Less payments / adjustments made Attorney's fees TOTAL above in the amount of $11220.51 computed as $9720.51 $0.00 $1500.00 $11220.51 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. B : Michael J. Doug erty,76046 07509470 C A Jer JHR Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 325 CHESTNUT STREET SUITE 501 PHILADELPHIA, PA 19106-2614 And that the last known address of the Defendant is x Cl= - M --? ELOISE G TOWNSEND x s. 0 w 2 MARYLAND CIR cam WHITEHALL, PA 18052 r=Q ?. rn IN THE COURT OF COMMON PLEAS LEHIGH COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. ELOISE G TOWNSEND Civil Action No. 2009-C-3362 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 , ELOISE G TOWNSEND 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 Defendant ELOISE G TOWNSEND 2 MARYLAND CIR WHITEHALL, PA 18052 is not in the military service. Further Affiant sayeth naught. AFFIANT SWORN TO AND SUBSCRIBED in my presence this day of NOTARY PT L IN THE COURT OF COMMONCPVLIE DS LE HIGH COUNTY, PENNSYLVANIA DISCOVER BANK Plaintiff vs. ELOISE G TOWNSEND Case No. 2009-C-3362 Defendant IMPORTANT NOTICE TO: ELOISE G TOWNSEND 605 SCHOLL AVE BETHLEHEM, i;!;? Date of Notice: YOU FAULT BECAUSE I PERSONALLY OR BY ATTORNEY AND D FILE TING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TEN N WR THE THIS LOSE YOUR TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU WI7HOUITHANHEAR NG AND ?OU MAYDATE NOTICE, A JUDGMENT MAY BE ENTERED AGAINST LAWYER , GO PROPERTY OR OTHER IMPORTANT RIGHTS. T HAVE YOU SHOULD TAKE THIS PAPER TO BELOW . vTH S OFFICE CAN PROVIDENYOOU WTHANF RMATION TO OR TELEPHONE THE OFFICE SET FORTH OVIDE YOU ABLE ABOUT HIRING A LAWYER. THIS MAY OFFICE IF YOU CANNOT AFFORD TO HIRE A LAWY OFFER LEGAL SERV ICES TO E IGIBRE PERSONS WITH INFORMATION ABOUT AGENCIES THAT MAY AT A REDUCED FEE OR NO FEE. BAR ASSOCIATION OF LEHIGH COUNTY LAWYER REFERRAL SERVICE 1114 WALNUT STREET ALLENTOWN, PA. 18102 TELEPHONE 610-433-7094 WELTMAN, WEINBERG & REIS CO., L.P.A. By: Michael Do erty P.A.I.D.# 76046 WELTMAN, WEINBERG & REIS CO., L.P.A. 325 Chestnut Street, Suite 501 Philadelphia, PA 19106 (215) 599-1500 (215) 599-1505 7509470 A Request for Military Status Department of Defense Manpower Data Center Ad& W Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 SEP-14-2009 07:26:35 < Last Name First/Middle Begin Date Active Duty Status Service/Agency TOWNSEND ELOISE Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. 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 Military. 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 Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly 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 active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further 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 current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: http://www,dgfcn.tlink.rnil/faq/pis/PC09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:BKLLPIBLYBJ IN THE COURT OF COMMON PLEAS OF LEHIGH COUNTY, PENNSYLVANIA - CIVIL DIVISION CASE SUMMARY CASE No. 2009-C-3362 Discover Bank § Location: Civil VS § Judicial Officer: McGinley, Carol K. Eloise G Townsend § Filed on: 07/02/2009 CASE INFORMATION Statistical Closures 09/30/2009 Judgment Entered Prior to Listing Plaintiff Discover Bank 6500 New Albany Road New Albany, OH 43054 Defendant Townsend, Eloise G 2 Maryland Cir Whitehall, PA 18052 PARTY INFORMATION Case Type: Civil Action Sub Type: Civil Action Complaint Case Flags: Arbitration Attorneys Dougherty, Michael J, Esq 215-599-1500(W) Retained DATE EVENTS & ORDERS OF THE COURT INDEX 09/30/2009 9:16 AM 07/02/2009 07/16/2009 07/22/2009 09/30/2009 03/08/2010 DISPOSITIONS. JUDGMENT Status: Active, Debtor: Eloise G Townsend, Creditor: Discover Bank, Amount: $11,220.51 EVENTS 0 Complaint and Notice to Defend Damages prayed in amt of $9,720.51 plus attys fees of $125.00 0 Arbitration Discovery Order: Discovery to be completed by 12129109. By the Court: /S/ C K McGinley, J. Copies 7114109 dktd 7120109. Sheriffs Return W Prae to enter Jdgt against dit for failure to respond. Jdgt entered in the amount of $11,220.51. Afdt of Non-Military, Important Notice & Exhibit, attached. Notice mid 09130109. Filed @ 9:16 a.m. Certification of Judgment to Cumberland County, Pennsylvania Exit g 0 n' OD 3m 0M _ z O rn ?. if c U) IF g0 6 ? a. I6 r 0 > n S, CL to 80& g.2 m' ? D o QCaai t3 m ? LT o30 m o C DATE, FINANCIAL, INFORMATION 07/02/2009 07/02/2009 Plaintiff Discover Bank Total Charges Total Payments and Credits Balance Due as of 3/8/2010 Charge Plaintiff Discover Bank Payment Receipt # 2009-17049 Plaintiff Discover Bank 167.50 170.75 (3.25) 131.25 (131.25) PAGE 1 OF 2 Printed on 0310812010 at 1:57 PM IN THE COURT OF COMMON PLEAS OF LEHIGH COUNTY, PENNSYLVANIA - CIVIL DIVISION CASE SUMMARY CASE No. 2009-C-3362 09/30/2009 Charge t P Plaintiff Discover Bank Receipt # 2009-25292 Plaintiff Discover Bank 17.50 (17.50) 09/30/2009 aymen Plaintiff Discover Bank 18.75 03/05/2010 03/0512010 Charge Payment Receipt # 2010-05090 Plaintiff Discover Bank (22.00) PAGE 2 OF 2 Printed on 03/08!2010 at 1:57 PM Zil{~ (~1'fi ~ ~ ~~~ J~ ~4~ n ? f ~ f . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. ELOISE G TOWNSEND Defendant JP MORGAN CHASE Garnishee No. 10-2126 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION BANK ATTACHMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Michael J Dougherty, Esquire PA LD. #76046 WELTMAN, WEINBERG & REIS CO., L.P.A. 325 CHESTNUT STREET STE 501 PHILADELPHIA, PA 19106 (215)599-1500 WWR#07509470 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 10-2126 CIVIL TERM ELOISE G TOWNSEND Defendant JP MORGAN CHASE Garnishee 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 ELOISE G TOWNSEND 2 MARYLAND CIR. WHITEHALL,PA 18052, Defendant 3. and against JP MORGAN CHASE 500 BENT CREEK BLVD MECHANICSBURG, PA 17050-1876 4. Judgment Amount $ 11,220.51 Interest 09/30/09 $ 344.92 Costs $ 304.75 SUBTOTAL: $ s O Costs (to be added by Prothonotary): $ ~4 50 PQ ~mJ WELTMAN, WEINBERG & REIS CO., L.P.A. 1'70. ~ 6 C,BF a .oo N .~- " a.5o ~- By: ~ ~ P ~ a 1 A Michael J Dougherty, Esquire D a.(o, ~5 Tf PA I.D. #76046 WELTMAN, WEINBERG & REIS CO., L.P.A. 325 CHESTNUT STREET STE 501 PHILADELPHIA, PA 19106 (215)599-1500 ~ a. eo pue(~ W WR#07509470 50 l.l.. c~.~'+~+ac~~i ~~ a~b~~ wnf~~~ PRAECIPE FOR WRIT OF EXECUTION - (MONEY1~D~MENTS) P.R.C.P. 3101 to 3149 ~I~'~(~ k ~~~~~ ~ IN THE COURT OF COMMON PLEAS OF CtXY~earlcir,~ ~ COUNTY, PENNSYLVANIA No. ~Jr ~ C~~wl ~ .gym Term 20 J.D. vs No. Term 20 E.D. PRAECIPE FOR WRIT OF EXECUTION (MONEY JUDGMENT) To the Prothonotary: ISSUE W/RIT O_F^EX~ECUTIO^N^IN~THE ABOVE MATTER, (1) DirecteeE~the Sheriff h~J ~f `~ 3fJY ~ CJ~ 1C j County, Pennsylvania; (2) against` 5'C' C~~.~T~x ~(>~C' fl(~ ^~~''~~ n T~C't(~ ~'~l Y WWII-~ ~~S ~ Defendant(s); (3) and against _~ (4) and index this wCCrit (a) ~gains~_.L_~ r . (b) again; ~. as a li~~ against the real property of the defendant(s) :in the na ,.. _. . __ .. describe grope -. C~~ r Gamishee(s); Defendant(s) and Ganiishee(s), the Garnishee(s) as follows: {Specifically . ~, S. ~ r~e~• (5) Amount due Interest from q ~30 ~~~-( Total Dated $ 2-~c~ ~ 5 i ~~~+ .. ~ ""-', Plus sts. Attorney for Plaintiff (s) NOTE Under paragraph (1) when the writ is directed to the sheriff of another county as authorized by Rule 3103 (b), the county should be Indicated. Under Rule 3103 (c) a writ Issued on a transferred Judgment may be directed only to the sheriff of the county in which Issued. Paragraph (3) above should be completed only if a named garnishee Is to be included in the writ. Paragraph (4) (a) should be completed only N Indexing of the execution in the county of issuance is desired as authorized by Rule 3104 (a). When the writ issues to another county indexing Is required as of course in that county by the prothonotary. See Rute 3104 (b). Paragraph (4) (b) should be completed only if real property in the name of a garnishee Is attached and indexing as a Ifs pendens is desired. See Rule 3104 (c). O ui N w J 0.. c~ Z G O O Q 0 ~ ~ Z ~ Z w ~ a O'~~ WO .F- Z ~, Z O t= W ~ x--m ~ ~ p E ci ~. ~ o ~ o ~ m M O o a: W~U U v ~" W 0.. ~, ;~ _.. P~ :«. C C o r r ~~ QO' ~ ~_ ~ d U~ ~ O A m ~~~ Q N a~ a '~ a WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-2126 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From ELOISE G. TOWNSEND, 2 Maryland Circle, Whitehall, PA 18052 (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: JP MORGAN CHASE, 500 Bent Creek Blvd, Mechanicsburg, PA 17050-1876 and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $11,220.51 Interest 9/30/09 -- $344.92 Atty's Comm Atty Paid $226.75 Plaintiff Paid Date: 4/13/10 (Seal) REQUESTING PARTY: Name MICHAEL J. DOUGHERTY, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO, LPA 325 CHESTNUT STREET, STE 501 PHILADELPHIA, PA 19106 Attorney for: PLAINTIFF Telephone: 215-599-1500 L.L. $.50 Due Prothy $2.00 Other Costs $304.75 Davi .Buell, Prothon tary By: Deputy Supreme Court ID No. 76046 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor Discover Bank vs. Eloise G Townsend SHERIFF'S OFFICE OF CUMBERLAND COUNTY i~tE~r~~ ~i ~:~,~~ ~~ ~'~ ~ ski-3~1sL.4~T~ 2~14MAY I2 AM 8~ S4 CU;v~~~~4~~~ ~~JUM#Y ~~NNS1~1.'stANtA Case Number 2010-2126 SHERIFF'S RETURN OF SERVICE 05/11/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that on April 28, 2010, attempted to attach as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Eloise G. Townsend, in the hands, possession, or control of the within named garnishee, JP Morgan Chase, 500 Bent Creek Blvd, Mechanicsburg, Cumberland County, Pennsylvania 17050-1876. At that time it was learned that this address is merely computer support staff only; this location has nothing to do with any type of financial records or any fiduciary responsibilities. An address was located at 225 Grandview Avenue, Camp Hill, Cumberland County, Pennsylvania 17011. This address is a Hewlett Packard Company software facility. This company has no affiliation with JP Morgan in any capacity; it is a misprint in the telephone book to list JP Morgan at that address. It was also learned that there are no other branches or facilities in Cumberland County affiliated with JP Morgan Trust. Therefore, this writ of execution is being returned as NOT FOUND. .,r, SO ANSWERS, ~/ May 11, 2010 RON R ANDERSON, SHERIFF ,' B ~' Sharon R. Lantz ~~ ~.. L~~-'~ ~.~~~- ~ uC ,' ~i WELTMAN, WEINBERG & REIS CO., L.P.A. BY: Michael J. Dougherty, Esquire I.D. No. 76046 325 Chestnut Street, Suite 501 Philadelphia, PA 19106 Phone: 215.599.1500 Fax: 215.599.1505 File #07509470 ~~ ~ ~.: Attorney for Plaintiff~~o .1Lf l ~~ ~j,` ~' . ~ `r C~;~; „, } DISCOVER BANK } CUMBERLAND County } Court of Common Pleas vs. } } } ELOISE G TOWNSEND } NO. 2010-2126 TO THE PROTHONOTARY: Kindly Dissolve Plaintiffs Writ of Execution as to Garnishee, JP MORGAN CHASE, in the above-captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. ~,/i Michael J. Dougherty, Esquire Attorney for Plaintiff ~ 8.0o PA AT1y a ~l Sl~3a