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HomeMy WebLinkAbout10-2802 r?F^Fl?riED-4-4--E 2010 APR 21 AM 9: 59 NTY cum IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: 10 -&802 w',?-Te-m vs. COMPLAINT IN CIVIL ACTION REBECCA L HARTMAN GIAN C MELENDEZ Defendants 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 08178494 C A Pit EMR O C.tit 454 (-q q8 0 aq1a.oo IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. REBECCA L HARTMAN GIAN C MELENDEZ Defendants Civil Action No 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. Defendants are adult individual(s) residing at the address listed below: REBECCA L HARTMAN 339 HERMAN AVE LEMOYNE, PA 17043 GIAN C MELENDEZ 339 HERMAN AVE LEMOYNE, PA 17043 3. Defendants applied for and received a credit card bearing the account number XXXXXXXXXXXX7862 . 4. Defendants made use of said credit card and has a current balance due of $3829.59 , as of February 10, 2010 5. Defendants 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 28.9906 per annum on the unpaid balance from February 10, 2010 . A copy of Plaintiff's Statement is attached hereto, marked as Exhibit 111" and made a part hereof. 7. Plaintiff avers that the Agreement between the parties provides that Defendants 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, Defendants have willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for Judgment in its favor and against Defendants , REBECCA L HARTMAN AND GIAN C MELENDEZ jointly and severally , in the amount of $3829.59 with interest at the rate of 28.990% per annum from February 10, 2010 plus attorneys' fees of $125.00 , and costs. James u. armnrouL,gG5zq WELT7sbrgh W INBERG & REIS CO., L.P.A. 436 nt Avenue, Suite 1400 PittPA 15219 (4124- 955 FAX: - 38-7130 0817 A Pit EMR This law firm is a debt collector attem?ti to collect this debt for l be used for that purpose. our client and any information obtained 1w s.rsvv,::. IF 1.1% $0.00 $835.00 CARD - --- -- ----- Payment Due Date February 26, 2010 31 SDSN6A01 0005695 REBECCA HARTMAN GIAN MELENDEZ 339 HERMAN AVE LEMOYNE PA 17043-1940 Enter Amount Enclosed Below $ `, , ? , a, ` , i.) c f.y i Go paperless and make your account Information more secure with password- protected statements only you can access. Learn more at discover.com/paperless. PO BOX 6103 1111111111rr1llrs1111111111 CAROL STREAM IL 60197-6103 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. 000001986458375822299000000 000000000083500 Discover More Card Account Summary Closing Date: January 31, 2010 page 1 of 1 Account number ending in 7862 Previous Balance $3,829.59 Payment Due Date February26, 2010 Payments And Credits 3,829.59 Minimum Payment Due $835.00 Purchases + 0.00 Credit Limit $3,000.00 Cash Advances + 0.00 Credit Available $0.00 Balance Transfers + 0.00 Cash Credit Limit $1,700.00 Finance Charges + 0.00 Cash Credit Available $0.00 New Balance $0.00 Cashback Bonuse Opening Cashback Bonus Balance $ 0.00 New Cashback Bonus This Period + 0.00 Cashback Bonus Balance $ 0.00 Cashback Bonus(D anniversary Month: March How Can We Help You? 1. Visit Discovencom to pay your b1l for no cost, view your 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 options or to speak with a Customer Service Account Manager Please have your Discover Card available. 3. Write us at Discover Card, PO Box 30943, For TDD (assistance for hearing impaired) see reverse side Salt Lake City, UT 84130 Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence. Trans. Post Date Date Payments and Credits Jan 31 Jan 31 INTERNAL CHARGE-OFF $ .3,829.59 ice' ~ Finance Charge Summary Nominal Transaction Average Daily ANNUAL ANNUAL Periodic Fee Daily Periodic PERCENTAGE PERCENTAGE FINANCE FINANCE Balances Rates RATES RATES CHARGES CHARGES current billing period: 13 days Purchases $0 0.07942% 28.99% F 28.99% $0 $0 'Cash Advances $0 0.07942% 28.99% F 28.99% $0 $0 The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above. 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Bulmollo) ail sn win ',12llol ,1noA ul slg6u noA sA,1asa,1d IOU 0!m as 6u!op ° Inq 'sn suogdolal ueo nOA pa,1eodde walgo,1d ,1o ,1o,1,1a ail 113!gm uo 0!q lsn) a4I noA luas am ,1al)e SAep g ueyl iolel ou not wa! ,1eag Isnw aM ° alq!ssod se uoos se Izvo-o L1r9 in A!0 axp lies 'LdbOE 1108 Od'wsaJOR ,1anoOs!O le ,1aded Jo laags ale,1edas a uo sn alum '0!q nay( uo uo!lOesue,1I o e Inge uo!lew,1olui aaw paau noA p ,10 '6uaM s1 luq not 4u!UI noA 11 1118 ,1noA lnogV suogSanO 10 SJO113 to aseO ul -hilwwng sitift Ou008 '999Z-L16-009-L IleO iAlale!pawwi l,1od%J •sPiea ualols uo 1501 junoo3y ,1noA to sw,1al agl Ile su!eluo3 )uawaa,1BV ,1agwawp,1eo ,1noA •juawasAy jagwswpae0 moA gag uogew,1o)ui luel,1odwi leuo0!ppe ,1o) abed qoea jo A3eq oqI gas luawalels Builpil s!4l of alled oua ue4l a,1ow s! a,1ail JI monew olul lueliodwl 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 Robert Adkins (Name) Senior Vendor Litigation Liaison 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 k , ' ormation and belief. gnature) WWR# 8178494 Rebecca L. Hartman 7862 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor ~gtlittti' pt ~Tt7i!{/rrfF~~ ~. _ F~i~.~ _ -.. _ ~~~ ~~i ~ror~ nAY I ~ aM 8: ~ (~;ht~ ~V~ N~f 1~~~I`~- Discover Bank vs. Rebecca L. Hartman (et a{.) Case Number 2010-2802 SHERIFF'S RETURN OF SERVICE 05/07/2010 06:42 PM -Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on May 7, 2010 at 1840 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Rebecca L. Hartman, by making known unto herself personally, at 339 Herman Avenue, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct copy of the same. TIM B C ,DEPUTY 05/07/2010 06:42 PM -Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on May 7, 2010 at 1840 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Gian C. Melendez, by making known unto Rebecca L. Hartman, adult in charge at 339 Herman Avenue, Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $58.40 May 10, 2010 TIM K, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF {d; Gouny5uita Sher'f. Tel~osoft. lnc. ,.,, "~~ r F!LG'.. ~ ry 2u10 J~._ -6 ~-~ 8~ ~-7 ,, CJ,a.~ ~ ~ ~~rv IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. REBECCA L HARTMAN GIAN C MELENDEZ No: 10-2802 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT Defendants 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 08178494 C A Pit SGM Judgment Amount $4185.04 ~ iN.ao pa.~~y ck ~ y6 y ~ 3 ~r~ K~ ryy~ y6 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 10-2802 CIVIL TERM REBECCA L HARTMAN GIAN C MELENDEZ PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONTARY: Kindly enter Judgment against the Defendants REBECCA L HARTMAN GIAN C MELENDEZ above named, in the default of an Answer, in the amount of $4185.04 computed as follows: Amount claimed in Complaint Less payments / adjustments made $3829.59 $o.oo Interest on the remaining principal balance of $3829.59 from April 07, 2010 to June 22, 2010 @ the interest rate of 28.9900 per annum $230.45 Attorney's fees TOTAL $125.00 $4185.04 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: Jam 08178494 C A Pit SGM Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 And that the last known address of the Defendants are REBECCA L HARTMAN 339 HERMAN AVE LEMOYNE, PA 17043 GIAN C MELENDEZ 339 HERMAN AVE LEMOYNE, PA 17043 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. REBECCA L HARTMAN GIAN C MELENDEZ Civil Action No. 10-2802 CIVIL TERM NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order of Judgment was entered against you on Q,~,,~,,, ~ ZO ( b ~~ (xx) Assumpsit Judgment in the amount of $4185.04 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 REBECCA L HARTMAN 339 HERMAN AVE LEMOYNE, PA 17043 By: GIAN C MELENDEZ 339 HERMAN AVE LEMOYNE, PA 17043 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. 10-2802 CIVIL TERM NON-MILITARY AFFIDAVIT REBECCA L HARTMAN GIAN C MELENDEZ 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 Defendants REBECCA L HARTMAN GIAN C MELENDEZ are 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. REBECCA L HARTMAN 339 HERMAN AVE LEMOYNE, PA 17043 GIAN C MELENDEZ 339 HERMAN AVE LEMOYNE, PA 17043 are 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 Jun-28-2010 07:12:33 Namet First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency HARTMAN REBECCA Based on the information you have furnished, the DMDC does not possess L 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 httn://www.defenselink.mil/faq/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 maybe 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.miUappj/scra/popreport.do 6/28/2010 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 Jun-28-2010 07:13:37 Namet First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency MELENDEZ GIAN C 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 htta://www.defenselink.mil/faq/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 maybe 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.miUappj/scra/popreport.do 6/28/2010 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. REBECCA L HARTMAN GIAN C MELENDEZ Defendant TO. REBECCALHARTMAN 339 HERMAN AVE LEMOYNE, PA 17043 Date of Notice: ~l~l ~/ 1~V ~~_ Case No. 10-2802 CIVIL TERM IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WfTH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTIGE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE 5ET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA. 17013 (717) 249-3166 WELTMAN~BERG &REIS CO., L.P.A. By: 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 8178494 A PIT T4S IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. REBECCALHARTMAN GIAN C MELENDEZ Defendant Case No. 10-2802 CIVIL TERM IMPORTANT NOTICE TO: GIAN C MELENDEZ 339 HERMAN AVE LEMOYNE, PA 17043 f Date of Notice: ~,/ ~~ r ~® ~- YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING W1TH 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, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT MIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA. 17013 (717) 249-3166 WELTMAN, W~.IRG & REIS CO., L.P.A. By: Matthew Urban P.A.I.D.# 90963 WELTMAN, WEINBERG & REI5 CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 8178494 A PIT T4S ,~ . FILEp-QFFIGE OF THE pR~}THQNOTARY 201.0 OCT l 5 P1~ 2~ 5 ~ GUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. REBECCA L HARTMAN GIAN C MELENDEZ Defendant SOVEREIGN BANK and MEMBERS I sT FEDERAL CREDIT UNION, Garnishee, No. 10-2802 CNIL TERM PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLI~ FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA LD. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#08178494 .- < IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. REBECCA L HARTMAN 339 HCrmQ.n Av~° GIAN C MELENDEZ ~ Lemoyr~. P-4 140N3 Defendant ~,~d S P ~01~ Ito$ g. ~i~, ~ SOVEREIGN BANK and ~~ MEMBERS 1ST FEDERAL CREDIT UNION, as i a Mas'Ice~ ~1' ,Gan,p N~i q , pA ~~oi l Garnishee Kindly issue a Writ of Execution in the above matter... PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: 1. 2. 3. 4. O ~a~/. s'a 58•~fo ga.oo 1'~. 00 a.so IQ~ ,~o directed to the Sheriff of CUMBERLAND County: Civil Action No. 10-2802 CNIL TERM +~, ~B s. o0 iB po0.0~ against REBECCA L HARTMAN and GIAN C MELENDEZ, Defendant against SOVEREIGN BANK and MEMBERS 1sT FEDERAL CREDIT UNION, Garnishee Judgment Amount Less payments of Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): ~~ CeF M n PD ATry ~a:~~~ ~~ a~~ ~7 $ 4,185.04 $ 185.00 $ 64.35 $ 4,064.39 WELTMAN, WE_JDLBPi~& REIS CO., L.P.A. By: ~" Matthew D. Urban, Esquire PA LD. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-2802 Civil CIVIL ACTION -LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From REBECCA L HARTMAN and GIAN C MELENDEZ, 339 Herman Avenue, Lemoyne, PA 17043 (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: SOVEREIGN BANK, 168 S. 32nd Street, Camp Hill, PA 17011 MEMBERS 1sT FEDERAL CREDIT UNION, 3512 Market Street, Camp Hill, PA 17011 and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $4,000.04 Interest -- $64.35 Atty's Comm Atty Paid $191.40 Plaintiff Paid Date: 10/15/10 (Seal), L.L.$.50 Due Prothy $2.00 Other Costs uell, Protho tart' By: Deputy REQUESTING PARTY: Name MATTHEW D. URBAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., LPA 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 90963 `~ 1 OCT S 12010 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. No. 10-2802 CNIL TERM T~i"i'ERROr.~TOI2IES li`t,~TT.~t;H~lEtiT SOVEREIGN BANK and MEMBERS 1" FEDERAL CREDIT UNION REBECCA L HARTMAN GIAN C MELENDEZ Defendant and SOVEREIGN BANK and. MEMBERS 1ST FEDERAL CREDIT UNION Garnishee FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P .A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#08178494 ~ , ,.,, _ ~-~ ~ ° o ~~ "~ ;;~ ~7 -~ -T'7 P'~'7 C,J) ~ N ~ C7 r"' .~:- - S'~ ~- ` ~~ :.~^ ..../' .' . t IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff ti5. Civil :lctiun Nt~.: 70-?g0~ ClViL TR~~i REBECCA L HARTMAN GIAN C MELENDEZ Defendant and SOVEREIGN BANK and MEMBERS 1ST FEDERAL CREDIT UNION Garnishee TO: SOVEREIGN BANK Suggested Reference No.: XXX-XX-3906 168 SOUTH 32ND STREET Suggested Reference No.: XXX-XX-7769 CAMP HILL, PA 17011 MEMBERS 1sT FEDERAL CREDIT UNION 3512 MARKET ST CAMP HILL, PA 17011 RE: REBECCA L HARTMAN GIAN C MELENDEZ 339 HERMAN AVE LEMOYNE, PA 17043 IMPORTANT NOTICES TO GARNISHEE! A. You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in Judgment against you. B. Herein, the word "defendant" means any one or more of the defendants against whom the writ of Execution is issued. C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to attachment which is then in the hands of the garnishee, it also attaches all property of the defendant which comes into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For example, the resultant liability of a Garnishee-Bank would not be measured by the balance in the debtor's account, either at the time of service of the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited and withdrawn during the intervening period. INTERROGATORIES IN ATTACHMENT 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason (including funds on deposit for checking or savin~zs accounts and certificates of deposit)? ~~ la. If the answer to Interrogatory 1 is in the affirmative, state the following: the amount of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof; the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written instruments and the present location of each of such instruments; the amount or amounts that defendant claims or claimed that you owe or owed to him; and the nature and amount of each of such liabilities. nta 2. At the time you were served or at any subsequent time was there in your possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant. ~ O 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or part by the defendant or in which defendant held or claimed any interest? ~O 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? 5. At any time before or after you were served, did the defendant transfer or deliver any property to you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof? n~ 6. At any time after you were served did you pay, transfer, or deliver any money or property to the defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the defendant against you? V 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, Identify each account and state the reason for the exemption, the amount being withheld under each exemption and the amount of funds in each account, and the entity electronically depositing those funds on a recurring basis. 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt fiords, did not exceed the amount of the ;eneral monetary exemption under 42 Pa.C.S. ~ g 1'_' ;? if so, identity each account. (1© ~cJ ~~ S 9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these interrogatories on this institution. n~~ 10. If the answer to Interrogatory 1 is in the affirmative, state the date the written instrument, checking or savings account, certificate of deposit, or other funds were frozen, restricted, or otherwise put on hold by this institution. ~' 11. If the response to Interrogatory 7 is in the affirmative, are other funds comingled in the account which are not deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? ~ 1~- 12. If the response to Interrogatory 11 is in the affirmative, state the amount ofnon-exempt funds on deposit in the account. 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#08178494 i ti VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is Tania S. Young (Name) Deposit Operations Analyst o fMembers 1st Federal Credit Union (Title) (Company) garnishee herein, that he/she is duly authorized to make this verification, and the facts set forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her knowledge, information and belief. (SIGNATURE SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~titr ~4 ~ix~trbrt~/ Jody S Smith ~4t ~~~ Chief Deputy ~s - `- , ;- Richard WStewart - - - Solicifor ~ c~~~~~_~-~~~ti~i~F Discover Bank Case Number vs. Rebecca L. Hartman (et al.) 2010-2802 SHERIFF'S RETURN OF SERVICE 10/21/2010 03:31 PM -Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on Octobe 21, 2010 at 1531 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendants, to wit: Rebba L. Hartman and Gian C. Melendez, in the hands, possession, or control of the within named garnishee, Sovereign Bank, 3556 Gettysburg Road, Camp Hill, Cumberland County, Pennsylvania 17011, by handing to Doris Dix, Branch Operations Manager, 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. 10/21/2010 03:16 PM -Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on Octobe 21, 2010 at 1516 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendants, to wit: Rebba L. Hartman and Gian C. Melendez, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 3512 Market Street, Camp Hill, Cumberland County, Pennsylvania 17011, by handing to Mary Bayer, Branch Manager, 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 October 22, 2010 to Rebecca L. Hartman at 339 Herman Avenue, Lemoyne, PA 17043 and to Gian C. Melendez at 339 Herman Avenue, Lemoyne, PA 17043. October 22, 2010 w ~ti~t~~ ""~"p ~ t'"tiP~ ~~. ~ ~`~ ZZ ~~~ O1~Z `~~~~~ Q~71.~ SO ANSWERS, M . RON R ANDERSON, SHERIFF a Gut 1, ~, , !c) CountySuite Shentf. Teleosott Inc. SHERIFFS OFFICE OF CUMBERLAND OUNTY Ronny R.Anderson Sheriff V Jody S Smith Chief Deputy Richard Wil Stewart Solicitor Discover Bank vs Rebecca L. Hartman (et al.) Case Number 2010-2802 SHERIFF'S RETURN OF SERVICE 10/21/2010 03:31 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn accordin g to law, states that on Octobe 21, 2010 at 1531 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendants, to wit: Rebbecca L. Hartman and ian C. Melendez, in the hands, possession, or control of the within named garnishee, Sovereign Ba nk, 3556 Gettysburg Road, Camp Hill, Cumberland County, Pennsylvania 17011, by handing to Doris D ix, Branch Operations Manager; 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. 10/21/2010 03:16 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn accordin 21, 2010 at 1516 hours, attached as herein commanded all goods, chattels monies of the within named defendants, to wit: Rebbecca L. Hartman and ( hands, possession, or control of the within named garnishee, Members 1st Market Street, Camp Hill, Cumberland County, Pennsylvania 17011, by har Manager, personally three copies of interrogatories together with three true of execution and made the contents there of known to her. I to law, states that on Octobe rights, debts, credits, and ian C. Melendez, in the -'ederal Credit Union, 3512 ling to Mary Bayer, Branch and attested copies of the writ The writ of execution and notice to defendant was mailed on October 22, 2 10 to Rebecca L. Hartman at 339 Herman Avenue, Lemoyne, PA 17043 and to Gian C. Melendez at 339 Herman Avenue, Lemoyne, PA 17043. 11/04/20,10 Ronny R. Anderson, Sheriff, who being duly sworn according, to law, states his writ of execution is returned STAYED. Defendants have filed for bankruptcy. SHERIFF COST: $169.71 November 04, 2010 SO B R ANDERSON, SHERIFF n R. Lantz ''. Cvu= , s:a :.- „°e,ff, TeeQSW.t. inc. P WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA)' NO COUNTY OF CUMBERLAND) TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff From REBECCA L HARrMAN and GIAN C MELENDEZ, 339 Herm: 17043 (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 of GARNISHEE(S) as follows: SOVEREIGN BANK, 168 S. 32°d Street, Camp Hill, PA 17011 MEMBERS 1sT FEDERAL CREDIT UNION, 3512 Market Street, Camp' and to notify the garnishee(s) that: (a) an attachment, has been issued; (b) the gar: paying any debt to or for the account of the defendant (s) and from delivering an (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is fi of anyone other than a named garnishee, you are directed to notify him/her that I garnishee and is enjoined as above stated. Amount Due $4,000.04 Interest -- $64.35 Atty's Comm % Atty Paid $191.40 Plaintiff Paid Date: 10/15/10 L.L.$.50 Due Prothy 52.00 Other Costs Civil , ACTION'- LAW Avenue, Lemoyne, PA in the possession PA 17011 shee(s) is enjoined from property of the defendant in the possession has been added as a iry (Seal) By: REQUESTING PARTY: Name MATTHEW D. URBAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., LPA 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412=434-7955 Supreme Court ID No. 90963 In Te aid' This Y UE COPY FROM RECORDand mony whereof:) here unto set my seal of said COUft At CSrlisle, P13 'cSaY +ot y Pn?? ry IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. No. 10-2802 CIVIL TERM ? INTIERROGA t RIES ITN'- ATTACHMENT I'ACHMENT SOVEREIGN BANK and MEMBERS 1'r FEDERAL CREDI'T' UNION REBECCA L HARTMAN GIAN C MELENDEZ Defendant and SOVEREIGN BANK and MEMBERS 1 ST FEDERAL CREDIT UNION Garnishee FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L_P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#08178494 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BAND Plaintiff REBECCA. L 1IARTMAN GIAN C MELENDEZ Defendant and C;vii .1 rion o.: 10-2802 ClI TER ,\d SOVEREIGN BANK and MEMBERS 1 ST FEDERAL CREDIT UNION Garnishee TO: SOVEREIGN BANK 168 SOUTH 32ND STREET CAMP HILL, PA 17011 Suggested Reference No.: XXX-XX-3906 Suggested Reference No.: XXX-XX-77.69 MEMBERS 1 IT FEDERAL CREDIT UNION 3512 MARKET ST CAMP HILL, PA 17011 RE: REBECCA L HARTMAN GIAN C MELENDEZ 339 HERMAN AVE LEMOYNE, PA 17043 IMPORTANT NOTICES TO GARNISHEE! A. You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in Judgment against you. B. Herein, the word "defendant" means any one or more of the defendants against whom the writ of Execution is issued. C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to attachment which is then in the hands of the garnishee, it also attaches all property of the defendant which comes into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For example, the resultant liability of a Garnishee-Bank would not be measured by the balance in the debtor's account, either at the time of service of the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited and withdrawn during the intervening period. INTERROGATORIES IN ATTACHMENT 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for anv reason (including funds on deposit for checking or savin<zs accounts and certificates of deposit)? NO 1.a. If the answer to Interrogatory 1 is in the affinnative, state the following. the amount of money you owe or owed to defendant, and, if such money is in the farm of a fund, the present location thereof; the terins, face amount and amount you owe or owed to defendant on each of such negotiable or other written instruments and the present location of each of such instruments; the amount or amounts that defendant claims or claimed that you owe or owed to him; and the nature and amount of each of such liabilities- 2. At the time you were served or at any subsequent time was there in your possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant. YES- SEE ATTACHED 3. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or part by the defendant or in which defendant held or claimed any interest? NO 4. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? NO 5. At any time before or after you were served, did the defendant transfer or deliver any property to you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof? NO 6. At any time after you were served did you pay, transfer, or deliver any money or property to the defendant or to any person or place ;pursuant to his direction or otherwise discharge any claim of the defendant against you? NO 7. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which funds are deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? If so, Identify each account and state the reason for the exemption, the amount being withheld under each exemption and the amount of funds in each account, and the entity electronically depositing those funds on a recurring basis_ NO 8. If you are a bank or other financial institution, at the time you were served or at any subsequent time did the defendant have funds on deposit in an account in which the funds on deposit, not including any otherwise exempt funds, did not exceed the amount of the general monetary exemption under 42 Pa.C.S. § 81.23? If so, identify each account. YES- SEE ATTACHED 9_ If the answer to Interrogatory I is in the affinnative, state the date the sheriff served these interrogatories on this institution. N/A 10. If the answer to Interrogatory 1 is in the affinnative, state the date the written instrument, checking or savings account, certificate of deposit, or other funds were frozen, restricted, or otherwise put on hold by this institution. N/A 11. If the response to Interrogatory 7 is in the affirmative, are other funds comingled in the account which are not deposited electronically on a recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or attachment under Pennsylvania or federal law? N/A 12. If the response to Interrogatory 11 is in the affirmative, state the amount of non-exempt funds on deposit in the account. N/A 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#08178494 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unsworn falsifications to authorities, that he/she is DONNLA M LONG (Name) LEAD SPECIALIST _ of SOVEREIGN -BANK , garnishee herein, (Title) (Company) that he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Answers to Interrogatories are true and correct to the best of his/her knowledge, information and belief. f' (SIG A RE) r +t? a 9`? a,.'?' ? ? 8 t' •_ k ?:. p^, "^,.?!??,s???.ke.. r'-- ??? < ?""? .. ANSWERS TO INTERROGATORIES Account # 0211117757 Balance: $487.49 After allowing for the $300.00 exemption under 42 Pa.C.S. 8123 the balance in this account is $187.49 Account Holder: REBECCA L HARTMAN 339 HERMAN AVE LEMOYNE, PA 17043-1940 Account # 0211117749 Balance: $.98 Account Holder: REBECCA L HARTMAN 339 HERMAN AVE LEMOYNE, PA 17043-1940 Account # 1161133232 Balance: $1.08 Account Holder: REBECCA L HARTMAN 339 HERMAN AVE LEMOYNE, PA 17043-1940 VERIFICATION I, Donna Long, Lead Specialist of Sovereign Bank, hereby verify that the information contained in the foregoing Answers to Interrogatories in Attachment are true and correct to the best of my knowledge, information and belief. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4094, relating to unsworn falsification to authorities. Sovereign Bank Donna Long Lead Specialist 1 "Sovereign 10a ??a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA I hereby certify that on or before the date of filing the following documents(s): Answers to Interrogatories in Attachment, Writ of Execution, Notice of Writ of Execution, Claim for Exemption Order and Claim for Exemption I have served a copy thereof on each of the following persons in the manner indicated below: Service by first class mail addressed as follows: Matthew D. Urban, Esquire Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 Service by certified mail addressed as follows: REBECCA L HARTMA 339 MERMAN AVE LEMOYNE, PA 17043-1940 i 1 Donna Long a Lead Specialist Sovereign Bank MA1 M133-02-10 2 Morrisey Boulevard Boston, MA 02125 November 1, 2010 WELTMAN, WEINBERG & REIS CO., L.P.A. BY: Matthew D. Urban, Esquire I.D. No.90963 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 8178494 DISCOVER BANK vs. REBECCA L HARTMAN GIAN C MELENDEZ and SOVEREIGN BANK and MEMBERS 1ST FEDERAL CREDIT UNION Garnishee(s) Attorney for Plaintiff(s) CUMBERLAND County Court of Common Pleas ? ilco NO. 10-2802 CIVIL z? vn r-- C-) TERN _ ., .?r PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter settled, discontinued, and ended as to Garnishee(s), SOVEREIGN BANK and MEMBERS 1ST FEDERAL CREDIT UNION, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By Matthew D. Urban, Esquire Attorney for Plaintiff Sworn to and subscribed Before me the _J ? Day ARY NOVEMBER, 2010 COMMONWEALTH OF PENN5Yl N:A Notarial Seal A. Jones, Notary Publk urgh, Allegheny County bn Expires June 29, 2014 Mem nnsvvania Association of Notaries cz? 0 N ap Ss Zr ~ C) Frim .r- zm a `:;18 P T". Pd #j PO Al-? u rb? h ? 0 q ,? ski ,010 a 503&ag