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Home My WebLink About10-2801q 2010 APR 27 Ail 9: 59 ;.)UN7Y IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. BRIAN C ARAGNO Defendant(s) No. 10 - 01801 a;vil - rk COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire PA I.D. #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#7660254 P qa, oo •Po Amy "q,D7a7(a7 1?-4, ay 1 99 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. BRIAN C ARAGNO Defendant(s) COMPLAINT IN CIVIL ACTION 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 ON AGENICES 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 Plaintiff is a corporation with offices at 6500 NEW ALBANY ROAD NEW ALBANY, OH 43054-0000. 2. Defendant(s) is/are adult individual(s) residing at the address listed below: BRIAN C ARAGNO 3 RICHLAND LN APT 1.01 CAMP HILL,PA 17011 3. Defendant(s) applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXX7440. 4. Defendant(s) made use of said credit card and has currently a balance due of $5,916.31 , as of FEBRUARY 24, 2010. 5. Defendant(s) is/are 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 23.40% per annum on the unpaid balance from FEBRUARY 24, 2010. A true and correct copy of Plaintiffs 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(s) 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(s) has/have willfully failed and/or refused to pay the balance due to Plaintiff. WHEREFORE, Plaintiff prays for Judgment in its favor and against Defendant(s), BRIAN C ARAGNO individually, in the amount of $5,916.31 with continuing interest thereon at the rate of 23.40% per annum from FEBRUARY 24, 2010 plus attorneys' fees $125.00, and costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. James C. Warrr PA I.D. #4252 WELTMAN, 1400 Kopper I 436 Sevent Pittsburgh, (412) 434 55 Esquire NBERG & REIS CO., L.P.A. lding 15219 WWR#:7b60254 $, mu a ruynienr vue raccounr 4umwr ending In /44U D15COVEK $0.00 V I $1,068.00 Enter Amount Enclosed Below CARD ???--- Payment Due Date $ January 30, 2007 31 SDSN6A01 0001287 BRIAN ARAGNO 5325 OXFORD DR APT 120 MECHANICSBURG PA 17055-4433 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 1t~Iill IInrIll III nr??r?lrr? CAROL STREAM IL 60197-6103 Address, e-mail or telephone change? Print change in space above, or go to Discover.com. Print your a-mail address to receive important Account information and special offers. 00000],986458980707562000000000000000106800 Discover More Card Account Summary Closing Date: December 31, 2006 page I of 1 Account number ending in 7440 Previous Balance $5 714 81 payment Due Date January 30, 2007 Payments And Credits , . 5,714.81 Minimum Payment Due $1,068.00 Purchases + 0.00 Credit Limit $4,200.00 Cash Advances + 0.00 Credit Available $0,00 Balance Transfers + 0.00 Cash Credit Limit $2,200.00 Finance Charges + 0.00 Cash Credit Available $0.00 New Balance a $0-00 Cashback BonuS® Opening Cashback Bonus Balance $ 0.00 New Cashback Bonus This Period + 00 Cashback Bonus Balance $ 0,00 Cashback Bonuse Anniversary Dale: September 12 V How Can We Hel 1 OU? p 1 • Visit Discover.com to pay your bill for no cost, view our latest Account information, earn and redeem rewardsoand 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. Trans. Post Date Date Payments and Credits Dec 31 Dec 31 INTERNAL CHARGE-OFF $ .5,714.81 Finance Charge Summary Average Daily Nominal ANNUAL ANNUAL Periodic Transaction Fee Daily Periodic PERCENTAGE PERCENTAGE FINANCE FINANCE Balance] Rotes RATES RATES CHARGES CHARGES current billing period: 19 days Purchases $0 0.06367% 23.24% V 23.24% $0 $0 Cash Advances $0 0.05477% 19,99% F 19.99% $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 Lost or stolen cards. Report Immediately! Call 11-00.347.2683. Z a, egikrg Rights Swnmary. In Case of Errors or Duesllons About Your Bill: If you think your bill is wrong, or if you need more information about a o transaction on your bill, write us on a separate sheet of paper at Discover Card; PO Box 30421, Soft Lake City, UT 84130-0421, as soon as possible. We must hear rom 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. N .The dollar amount of the suspected error. L4 .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 quesUOn. 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., H 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 havt this protection only when the purchase price was more than S50 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 lop 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 hems with your ppa?yment if you send the payment to any other address or If you use an envelope other than "the one provided. Payments received on of after 1 PM 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, YL 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 this statement and yyour 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 electrohic 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 pavment. 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 eabh statement You can cancel a ppaayyment, 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 o believe that our report is naccurato or inc mp report please write us at the following address: Discover Classic Card Pa Box 15316, Wilmington DE 19850.5315. Please include your name, address, home telephone number and Account number. PERIODIC FINANCE CHARGES. Periodic Finance Char es are imposed on all transactions from the date the transaction is posted, to your Account until the dale you gents entire New Balance by m2kinp payments or receiving credits. However we will provide the foBOwin9 grace period." If You Paid the New a anee on your previous billing states aY the Payment Due Date shown on (hat statement, and you pay the New Balance by Ihe Payment Due Date on this slalemehl we will not impose Periodic nance 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 hose new purchases.There Is no grace period on balance transfers or cash advances. We sort your transactions into groups of purchases, cash advances, and balance transfers and then further sort the transactions within each group by then Aniluai Percentage Rate. For example ,purchases sublI'ecl to a Promotional tale and purchases subject to a standard rate would be separate groups. We refer to those groups as iransacUon cafegorills. Al lho entl of each Dilimg periotl, we compute balances and Periodic finance Charges for each da of the DIIl;n9 period for each transaction category. We use the following equation to comppute Periodic Finance Char es for each lransacbon categor>X Average Dairy Balance x number of days In till bitting period x Daily Periodic bate. ?9ee the lnance charge summar? on your statement for these amounts. Than we add up the Per'i.dC Finance Charges for each transaction category to gel till total Periodic Finance Charges for your Account The verage Daily Balance is shown as zero it, because of the grace period, no Periotlrc Finance Charges apply to the balance m 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 Dairy Balance for each transaction category by adding up all the daily balances in a billin period for a transaction categgoryy and dividing the total b the number of days In the billing cycle; a compute the daily balance for each transaction category on each day by lirsl adding the Tollowing to the previous day's daily balance: transactions made that day, tees charged that day and Periodic Finance Charges accrued on the pfovious day s daily balance; and b then subtracting any credits and payments that are applied against the balance of the transaction category on that day. In calcula mg the daily balance for the previous billing period, we consider the "previous day's daily balance" to have been zero on the first day o the billing period. if a transaction is posted to your ecount 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 Finonce Charges which are added to the applicable balance transfer transaction category. When the special role 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. VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities, that he is an attorney for the Plaintiff herein and makes this Verification based upon the facts as supplied to him by the Plaintiff because the Plaintiff is outside the jurisdiction of the court and the Plaintiff's Verification cannot be obtained within the time allowed for the filing of this pleading; and that the facts and circumstances set forth in this pleading, are true and correct to the best of his knowledge, information and belief. 1 ,~~7~r'f 11~ ... h r"~ ~ ~ ~,;,', `v ~`1i~1 IN THE COURT OF COMMON PLEAS MBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. BRIAN C ARAGNO Defendant No: 2010-2801 PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warn-brodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, ~A 15219 (412) 434-7955 FAX: 4.12-338-7130 07660254 C A Pit SGM Judgment Amount $6498.99 41+}•00 PO AT'hj ~# ~ s~sol ~"' a~sa3o !~, ua~1 IN THE COURT OF COMMON PLEAS MBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. BRIAN C ARAGNO TO THE PROTHONTARY: Kindly. enter Judger in the default of an A Amount claimed in Less payments / ad Interest on the re $5714.81 from F @~-the interest rat Attorney's fees TOTAL I hereby certify t. been mailed in accorda Notices. Civil Action No. 2010-2801 PRAECIPE FOR DEFAULT JUDGMENT :nt.aganst the Defendant BRIAN C ARAGNO above named, ~~swer, in the amount of $6498.99 computed as follows: 'omplaint $5916.31 ustments made $0.00 aining principal balance of bruary 24, 2010 to June 30, 2010 of 23.2400 per annum $457.68 $125.00 $6498.99 at appropriate Notices of Default, as attached have ce with PA R.C.P. 237.1 on the dates indicated on the WELTMAN, WEINBERG & REIS CO., L.P.A. Plaintiff's address is: c/o WELTMAN, WEINBERG & 4..36 Seventh Avenue, Sui And that the last known BRIAN C ARAGNO 3 RICHLAND LN APT 101 CAMP HILL, PA 17021 By: James 07660254 REIS CO., L.P.A., to 1400 Pittsburgh address of the De. Pit SGM ' iPA 15219 endant is DISCOVER BANK Plaintiff vs. BRIAN C ARAGNO TO: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Civil Action No. 2010-2801 NOTICE OF JUDGMENT OR ORDER ( ) Plaintiff (xx) Defendant ( ) -Garnishee You are hereby not'fied that th~ ~ollowing Order of Judgment was entered agains you on y 1¢ ~p (xx) Assumpsit Jud ent in the amount of $6498.99 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisf'ed within sixty (60) days, your motor vehicle operator's li ense and/or registration will be suspended by the Depart ent of Transportation, Bureau of Traffic Safety, Harrisburg, P . (xx) Entry of ( ) ( ) (xx) ( ) ( ) By: BRIAN C ARAGNO 3 RICHLAND LN APT 101 CAMP HILL, PA 17011 Plaintiff's address is :nt of Court Order Non-Pros Confession Default Verdict Arbitration Award notary /s~ ~. c/o WELTMAN, WEINBERG REIS CO., L.P.A., 436 Seventh Avenue, Su to 1400 Pittsburgh, PA 15219 (412) 434-7955 DISCOVER BANK Plaintiff vs. BRIAN C ARAGNO The undersigned; states as follows: IN THE COURT OF COMMON PLEAS MBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Civil Action No. 2010-2801 NON-MILITARY AFFIDAVIT first duly sworn, according to law, deposes and That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further st tes 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 st tes that based upon investigation it is the affiant's belief that the Defend nt BRIAN C ARAGNO is not in"military service. Affiant further st tes that this belief is supported by the attached certificate from the D fense Manpower Data Center (DMSC), which states that the DMDC does not poss ss any information indicating the individual status. BRIAN C ARAGNO 3 RICHLAND LN APT 101 CAMP HILL, PA 17011 is not in the mili~ary service. Further Affiant sayeth naught. Request for Military Status Page 1 of 2 i Department of Defense M power Data Center Jul-06-2010 06:05:13 Military Statu Report Pursuant to th Service Members Civil Relief Act Namet First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency ARAGNO BRIAN C Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. Upon searching the inform tion 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). ~~ ~-a~.- Mary M. Snavely-Dixon, irector Department of Defense - anpower Data Center 1600 Wilson Blvd., Suite 4 0 Arlington, VA 22209-2593 The Defense Manpower Da a Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enro lment and Eligibility Reporting System (DEERS) database which is the official source of data on eli ibility for military medical care and other eligibility systems. The DoD strongly supports he enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (S RA) (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 ac ive 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 d ty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain furthe verification of the person's status by contacting that person's Service via the "defenselink.mil" URL htt : /www.defenselink.mil/fa / is/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 ainst you. See 50 USC App. §521(c). If you obtain additional i middle name), you can s~ for that query. This response reflects ac within the preceding 367 contact. ation about the person (e.g., an SSN, improved accuracy of DOB, a your request again at this Web site and we will provide a new certificate duty status including date the individual was last on active duty, if it was 's. For historical information, please contact the Service SCRA points-of- httnc•//www ~lmrlc.n~rl mil/a~ni/~cra/n~nrennrt ~ln 7/f /2(11 O WELTMAN, WEINBERG & REIS, C ., L.P.A. BY: Matthew Urban P.A.I.D.# 90863 436 Seventh Avenue, 1400 Kopper Building Pittsburgh, PA 15219 Phone: (412) 434-7955 7660254 A PIT 74S V vs. BRIAN C ARAGNO TO: BRIAN C ARAGNO 3 RICHLAND LN APT 101 CAMP MILL, PA 17011 DATE/FECHA: YOU ARE IN DEFAULT BECAUSE ENTER A WRITTEN APPEARANC'. ATTORNEY AND FILE IN WRITIN( YOUR DEFENSES OR OBJECTIOI SET FORTH AGAINST YOU. UNLI TEN DAYS FROM THE DATE OF l JUDGMENT MAY BE ENTERED A~ A WEARING AND YOU MAY LOSE OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER ONCE. IF YOU DO NOT NAVE A L TELEPHONE THE OFFICE SET FC OFFICE CAN PROVIDE YOU WITI- ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO Hli; OFFICE MAY BE ABLE 70 PROVI INFORMATION ABOUT AGENCIE~ LEGAL SERVICES TO ELIGIBLE F REDUCED FEE OR NO FEE, Attorney for Plaintiff COURT OF COMMON PLEA; OF CUMBERLAND COUNTY CASE N0.2010-2801 'OU HAVE FAILED TO PERSONALLY OR BY WITH THE COURT S TO THE CLAIMS SS YOU ACT WITHIN iIS NOTICE, A AINST YOU WITHOUT 'OUR PROPERTY OR 'O YOUR LAWYER AT ~WYER, GO TO OR NTH BELOW. THIS INFORMATION A LAWYER, THIS ~E YOU WITH THAT MAY OFFER :RSONS AT A USTED ESTA EN REBELDIA PORQUE A FALLADO DE REGISTRAR COMPRARECENCIA ESCRITA POR Si MISMO O A TRAVES DE UN ABOGADO Y SOMETER CON LA CORTE SUS DEFENSAS U OBJECCIONES A LOG CARGOS QUE SE HAN PRESENTADO CONTRA USTED. A MENOS QUE USTED ACTUE DENTRO DE DIEZ DIAS DE HABER RECIBIDO ESTE AVISO, LA CORTE PUEDE TOMAR UNA DECISION EN CONTRA SOYA SIN TENER DERECHOS A UNA VISTA Y USTED PUEDE PERDER 5U PROPlEDAD U OTROS DERECHOS IMPORTANTES. USTED DEBE LLEVAR ESTE DOCUMENTO A SU ABOGADO iNMEDIATAMENTE. SI USTED NO TIENE UN ABOGADO, LLAME O VAYA A LA SIGUIENTE OFICINA. ESTA OFICINA PUEDE PROVEERLE lNFORMACION A CERCA DE COMO CONSEGUIR UN ABOGADO. SI USTED NO PUEDE PAGAR POR LOS SERVICIOS DE UN ABOGADO, ES POSIBLE QUE ESTA OFICINA LE PUEDA PROVEER INFORMACION SOBRE AGENClAS QUE OFREZCAN SERVICIOS LEGALES SIN CARGO O BAJO COSTO A PERSONAS QUE CALIFICAN. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA. 17013 (717) 249-3166 WELTMAN, V~ BER REIS CO., L,P.A. ., 8 . ---- atthew Urban P.A.I.D.# 90983 WELTMAN, WEINBERG &REIS CO., L.P,A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 7660254 A PIT T4S WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-2801 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s) From BRIAN C. ARAGNO AT 3 RICHARD LANE APT 101 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 MEMBERS 1sT FCU AT 1711 SPRING ROAD CARLISLE, PA 17013 AMERICHOICE FCU AT 20 SPORTING GREEN DR. MECHANICSBURG, PA 17050 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 $6,498.99 Interest $246.78 Atty's Comm % Atty Paid $174.50 Plaintiff Paid Date: 3!11/11 (Seal) L.L.$.50 Due Prothy $2.00 Other Costs uell, Prot onotary By: 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 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 vs. BRIAN C ARAGNO Defendant(s) MEMBERS 1 ST FCU AMERICHOICE FCU Garnishee(s) o "?tl• su '?? OYhito I // S C) ?N G l? L' ?? t r A-f J(-H 'SD? COdl b Dj M a C/-70 No. 2010-2801 PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: . _ u. r --- --- -ca 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 /Z& ef'; %Y'4e LC WWR No. 7660254 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 2010-2801 BRIAN C ARAGNO Defendant(s) MEMBERS 1 ST FCU AMERICHOICE FCU Garnishee(s) 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 BRIAN C ARAGNO , Defendant 3. against MEMBERS 1 ST FCU, AMERICHOICE FCU, , Garnishee 4. Judgment Amount $ $6,498.99 Interest $ $246.78 Costs $ SUBTOTAL: $ $6,745.77 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 WWR No. 7660254 SHERIFF'S OFFICE OF CUMB Ronny R Anderson Sheriff ?p??xtr of ?stu?btr?,??? Jody S Smith Chief Deputy` y..`r " Richard W Stewart Solicitor c? ri E 'hE a-ERIrF ERLAND COUNTY OF TH;r pRO HO.Vo 1011 MAR 23 AM to: 5s CUMBERLAND COUNTY PENNSYLVANIA, Discover Bank Case Number vs. 2010-2801 Brian C. Aragno SHERIFF'S RETURN OF SERVICE 03/21/2011 12:15 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 21, 2011 at 1215 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Brian C. Aragno, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1711 Spring Road, Carlisle, PA 17013, Cumberlanc County, Pennsylvania, by handing to Nurdinah Williams, 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. 03/21/2011 01:13 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 21, 2011 at 1313 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Brian C. Aragno, in the hands, possession, or control of the within named garnishee, AmeriChoice Federal Credit Union, 20 Sporting Green Drive, Mechanicsburg, Cumberland County, Pennsylvania, by handing to Christine Crumoich, Customer Service Representative, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on March 23, 2011 to Brian C. Aragno, 3 Richland Lane, Apartment 101, Camp Hill, PA 17011. SO ANSWERS, March 22, 2011 RON R ANDERSON, SHERIFF i liam Cline, Deputy {c CountySuite Shen`f. Te!eosaft Inc. 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 # 7660254 DISCOVER BANK CUMBERLAND County Court of Common Pleas vs. C-) N C-71 BRIAN C ARAGNO -o ?-n NO. 2010-2801 co y :::o '0 On and c?nr off? sT ? c MEMBERS 1 FCU t -o 5-n AMERICHOICE FCU _ ? Garnishee(s) N PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter discontinued and ended as to Garnishee(s), MEMBERS 1 ST FCU AMERICHOICE FCU, only. WELTMAN, WEINBERG & REIS CO., L.P,? By Matthew D. Urban, Esquire Attorney for Plaintiff Sworn to and subscribed Before t e_ Z'Q day of MARCH, 2011 --- ------ ---- NOTARY`?P LIC COMMONWEALTH OF PENNSYLVANIA tl Wen Notarial Seal it y CI e d Gauk Notary Public ?' ttsburgh, Allegheny County county (i 1 'j/,, 7 -7 ? My Co, mmission (1 ,t ?i?p5 July 15, 2014 `h"pennsvivania Association of Notaries ?('? /37 p WELTMAN, WEINBERG & REIS CO., L.P.A. BY: Sarah E. Ehasz, Esquire Attorney for Plaintiff(s) I.D. No.86469 =_- ° - - , 436 Seventh Avenue, Suite 1400 CJ- rn .? -? r ri p,.... Pittsburgh, PA 15219 - N 'C s C D Phone: 412.434.7955 - Fax: 412.434.7959 File # 7660254 DFO a -- a +. C CU DISCOVER BANK Plaintiff Cumberland County Court of Common Pleas vs. NO. 2010-2801 BRIAN C ARAGNO Defendant(s) 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, WEINBERG & REIS CO., L.P.A. By rah E. Ehasz, E ire Attorney for Plain Sworn to and subscribed Before me the 2 \day of , 2011 N RY PUBLIC COMMONWEALTH OF PENNSYLVANIA NMt%l Seal f Wendy L. Gault, N00" "c CIty or h, m 152014 Member: n19 Notaries ky alp} 99777-9 ?o')5?V7S SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r lLEO-OF{= tCir Sheriff D!` THE PROTHONOTAR Jody S Smith Chief Deputy 20 SEP -2 PM 2; 3 7 Richard W Stewart Solicitor QFFi >',E 3-ERIFF CUMBERLAND OOUNI" Y PENNSYLVANIA Discover Bank Case Number vs. Brian C. Aragno 2010-2801 SHERIFF'S RETURN OF SERVICE 03/21/2011 12:15 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 21, 2011 at 1215 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Brian C. Aragno, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1711 Spring Road, Carlisle, PA 17013, Cumberlanc County, Pennsylvania, by handing to Nurdinah Williams, 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. 03/21/2011 01:13 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 21, 2011 at 1313 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Brian C. Aragno, in the hands, possession, or control of the within named garnishee, AmeriChoice Federal Credit Union, 20 Sporting Green Drive, Mechanicsburg, Cumberland County, Pennsylvania, by handing to Christine Crumoich, Customer Service Representative, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on March 23, 2011 to Brian C. Aragno, 3 Richland Lane, Apartment 101, Camp Hill, PA 17011. 08/31/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $147.84 (PAID) August 31, 2011 SO ANSWERS, RON R ANDERSON, SHERIFF 0? -00 f r4 . co .-zr LIpa ????35 ;C) Coun fSURP Sheriff. TeleoSsft. Im-,