The URL can be used to link to this page

Home My WebLink About10-4113 2010 J L' A 18 A; i 2: J 7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: 10- 14113 (Ivik-Rm VS. KELLY D GREEN COMPLAINT IN CIVIL ACTION Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 07887785 C A Pit EMR (p) ga.oo Po ATrY o ay39&L IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No KELLY D GREEN Defendant COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER 1,EGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff, DISCOVER BANK is a corporation with offices at 6500 NEW ALBANY ROAD NEW ALBANY , OH 43054 . 2. Defendant is adult individual(s) residing at the address listed below: KELLY D GREEN 3 HILL ST MT HOLLY SPGS, PA 17065 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX0258 . 4. Defendant made use of said credit card and has a current balance due of $4195.16 , as of October 09, 2009 5. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff. 6. Plaintiff is entitled to the addition of interest at the rate of 28.990% per annum on the unpaid balance from October 09, 2009 . A copy of Plaintiff's Statement is attached hereto, marked as Exhibit "1" and made a part hereof. 7. Plaintiff avers that the Agreement between the parties provides that Defendant will pay Plaintiff's attorneys' fees. 8. Plaintiff avers that such attorneys' fees will amount to $125.00 . 9. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for Judgment in its favor and against Defendant , KELLY D GREEN individually , in the amount of $4195.16 with interest at the rate of 28.990% per annum from October 09,'2009 plus attorneys' fees of $125.00 , and costs. fames c. WELTMAN, 436 Seve Pittsbux (412) FAX: 4078877J- This law firm is a debt collector attempti our client and any information obtained wi NBERG & REIS CO., L.P.A. Avenue, Suite 1400 PA 15219 955 8-7130 A Pit EMR to collect this debt for be used for that purpose. CARD 15 SDSN6A01 0004874 KELLY GREEN 3 HILL ST MT HOLLY SPGS PA 17065-1308 qY, 171. 10 I Enter mmounr rnciosea Heiow Payment Due Date $ October 10, 2009 Please make check payable to Discover Card. MinimuANN nt due includes a past due amount 00. Address, e-mail or telephone change? Print change in space above, or go to Discover.com, Print your e-mail address to receive important Account information and special offers. Will your payment get to us on time? Pay your bill online and your payment can be made to your account on the same day. Visit Discover.com/payments today. PO BOX 6103 Illll11If fill 111111lul,1ll CAROL STREAM IL 60197-6103 111111 111,1111111111,lr,r1r1If ,rIf IIIIr,?,rl1r11ur,r(11111. 000001986618281740543041951600000000419516 Discover More Card Account Summary Closing Date: September 15, 2009 page 1 of 1 Account number ending in 0258 Previous Balance $4 195 16 Payment Due Date October 10, 2009 Payments And Credits , . 0 00 Minimum Payment Due $4,195.16 Purchases . + 0 00 Credit Limit $4,800.00 Cash Advances . + 0 00 Credit Available $0.00 Balance Transfers . + 0 00 Cash Credit Limit $0.00 Finance Charges . + 000 Cash Credit Available $0.00 New Balance _ $4,195.16 Cashback Bonus® Opening Cashback Bonus Balance $ 0,00 New Cashback Bonus This Period + 0.00 Cashback Bonus Balance $ 0.00 CashbackBonus&Anniversary ------- -------------- ----------- ------------- January 15 How Can We Hel You? I. Visit Discover.com to pay your bill for no cost, view your p 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 selFservice 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 HIBIT E Finance Charge Summary Average Dail Daily P i di Nominal ANNUAL PERCEN ANNUAL Periodic Transaction Fee y al c er o c Rates TAGE RATES PERCENTAGE RATES FINANCE CHARGES FINANCE CHARGES current billing period: 15 days Purchases $0 Cash Advances $0 0.07942% 0 07 28.99% F 28.99% $0 $0 . 942% 28.99% F 28.99% $0 $0 The rates that apply to your Account are either fixed (F) or they may vary (V) 03 noted above mportant IMormatlon. If there Is more than one page to this billing statement see the back of each page for additional important information. ;ee your Cardmember Agreement. Your Cardmember Agreement contains all the terms of your Account o Z .oat or :talon cards. Report Immediately! Call 1-800-947-2683. Z HIIIng RIehis Summ?rY In Case of Errors or questions About Your Bill: If you think your bill Is wron 'Lake If yyoou need more Information about a o ransACtloiI your bill, write to us on a separat?ee sheet of aopeer at Discover Card PD Box 30421 Sal Lake C!tv UT 84130-0421 as soon as oss!ble. We must hear from you no later than 60 days after we sent you the firsf bill on which fhe error or problem appeared. Vou can telephone °o s but doin? so will not preserve )your rights. In your letter, give us thb following Information: o Your nam and Accoun numbe . The dollar amount of the suspected error p 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 N ou do not have top any amount in uesUon while we are invest) aUn ,tut ou are still Doll ated to the arts of your bill that are not In luestion. While we ina tiOgate your question, we cannot report you as del?nquerft or take any ac?lon to c11 et the amount you question, al Rye r Credtt Cab Purchases: IT yqU have a problem with the quality of 9?Ods or services that you Mount with a credit card, and bu have triedn good faith to correct the pproblem with the merchant y?oou may not Piave to pa the remalnln mount due on the moods or services. ou have this protgctlon only when the purchase price was more than S50 and the purchaseas made in yoor home state or with lTl 100 miles of vur mallin address. IT we own or o rate the merchant or IT we mal?fed you the advertisement for the goods or services, all purchases are covered egardless ? the amount or location gi purchase) avm is Send onlyy0urpaymotif and th to Mon of this statement n the a vetope rovlded D not send cash. gv send)r? our ch k as lees icrebbed above, voU aUthoPiag us to use In1orreia 0 on y?oour cheek to ma?e an erectrolcpfund transfer from your account at tn?L ?Inancia(? nstitution indicated oneour check or to process the?pavtiient as a check transaction. If epayment is processed as an electronic fund transfer, the ransfer will be for the mount of the check. When 6Ose information from your check to make an electronic fund transfer funds may, be v!thdrawn from your account as soon as the same day we receive your payment and you will not receive your check back from your nancial nstitutlon. The processes of Your payment may be del: ed If you send cash comespppooondence or other Items with Your payment, If you send the payment to inY other addross or iT you use an enveloppee oth r tharf the one provl'ded. ents received on or after 1 PM at bur processin Tacilityv hlondaYY ug as of The next business d Y If yvoou. have mispl cod vaUr envelo?e htoh Frldav or on a weekend ar hank holiday tylll be posted to .VIOUr Acc unt ;end your pa'ment to Discover Bank PO Box 6103 Card), Stream iL 60137-6103. Please allow 7-10 days 6r del!very.lf ydui paylhe t is• return d' e alt), r rrYserve the n ht to resutimit it as an electronic debit You can paaayv dvoour minlnum payyment or a greater amount over the tolephone, and you can set u autamaUc payments. Call us at 1-800-347-2683. rou will need ttsis statement arQii}rour bank account Information. You must en tiro that gufflclent ftPnds aro available in your bank account and all tions must comply with U.ss. law. You will be asked to prgvide the,Tl_rst digits oT your ?ccounfLStatemen azi? cowd_e? Bar enteMn? th°Sk ,.?,e ran w sac 'or you cdn seifect an amount cacti as the Minimum Payment Due or na notify us d phone at 1-6UU-347=zvM ooarvDy mau at the aaaress nuou in tno icvivua lcy?a n. ?, .?..w .w. .. Y.....,., .•...••.. «..• Indicated on tthhdentmollthlyts menht baUdrdn trrfledits or paaymmends apply during the billing cjclle tom: c Fw ant amou t ma be less than 'redlt RMorting. We may re R Information about your account to credit bureaus.. Lvamte ptavmSents, missed pa ments, or other pdefaults on your ancpcnothuntlmva? bbeellroilettec?lru our ISltinaCC ratweorbincom ero?e°rtleA thwtrl!?to usd lathe tollrnaltory address. Disccover Card, PO Bdx 15316ghNilmingtonh 5E 19950=5 16. P ease IancQude your name, abdress, home teieplione number and account sum c 3race Period on Purchase: at least 26da? We begin to impose Periodic Finance Char es on all transact) ns from the Transaction Date for the ransaction as shown on Your billing statement) unlasstransaction is posted to your Accouf!t after th e cl a oT the billin period in which it occurs, n which cca?se we be9In fo Imppoose Periods Finance Charrlges o?f that transacton Trom the Tirst da of the bl Iingg ppeeriod In Qvhich it Is pa9t?ed to your 4ccount We continue to impdsa PeriodicInance Charged until the date ou aY our entire Newy Balance, TnBkinQ ppaayymments or recei g credits. New Balance on youriprevlous bl++` statementl?eYeyvment Due Date Shown that blldrl$3tatempent and you?sthe 40wever, it youypaid the Ee tthhe motif Due Date on yyoou current bl n statementfl will nM Impose Periodic Finance Char es n new urchases to Vew Balanc b purchases first apPeariXg on the current biging statement call this a °groce period ^ There is no grace perlod9on balance transfers or cash advances. Fl Mss an $.50 ncwould e C :roe.se be will One you a minimum FINANCE CHARGE of 5.50 for any billing period in which Periodic Finance Charges of Annual Fee. If Vn our Account has an annual fee, It will be billed at the be Inning of each anniversary gear your Account IS open. The amount of Ile fee the statement when the fee Is billed. The annual fee I? not refundable unless you otl us t at you wish to close your Account +;.'J !r 3aopTears6ars of the mall!r.g or drl v-p date of the statement on which the fee is billed. you wUl receive this refuted even if you use your Card outing that peltod. Perlodle Finance Chafes. R so your trans ctlons ?e Into roups oT urchases, cash advances and balance transfers and then further sort the transactions in eacff grouer Annualrcenta fate. for e'amDand purchases subect to a tandard rate would b4 srou We refer t? the oups as tranaIod, we compub lances nd Periodic Finance Ch9eaC y oT the billing Tor each taualoto compute Pertodlc Finance Charges each traction category. (Average Dally Balance) times (days in billing period) times (Daily Periodic Rate). (You may refer to the finance char a summar, on your billin statement Tor th amounts.) Then we add u t Periodic Fin nce Charges for each transaction cats qory to et the to Periodic Finance Char?sg for Your Account?he Averag Daily Balance Ig shown as zero Iti? because of the grace period, no Per!o6icFina?ce Charges a pI tp the balance ih a trarisactlon ca!te?pty We use the Avera a Dail Balance (pill udln new transactions) method oT c31c01aUn talance upon which we laose Pedodlc Finance b111n period for a Char es. We com utd the lYvera a Datl lane for each transaction ca add!r?g he he ball the daily balances in a i tran ello C'M and d!v!din$ the tal by the number of days in thII eriod. wle computethe ddit balance for eat?l transaction catefory on, ch Cacatea gs addlmg the Tollowinq to tne?revious daXs Oalix bahance: ansactions witha Transaction Date of that dayach case on you . ?.......,..e.,., t r -jr a rroint fter the rinse of the hillinn ner!od In which It occurs. In the "c' for tti$ Tlrs't dir, of the burn eriod, we coASider the on the last day ofur Drevious AIRg erlod. o with the ioriof Cash AdvarLee Transaction Fee ahdTronsac?lon Fee rinance Chaves which a expires, we move the un i balance of the balance ^hase transaction catenoi However. If the special rate has May.24. 2010 8:23AM No, 2030 P. 21 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. 44904 relating to unsworn falsifications to authorities, that he/she is IJJ (Na e ACCOUNT MANAGER of DFS SERVICES LLC , plaintiff herein, that (Title) (Company) he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief, Sig re) WWR# 7887785 DFS# 6011298805420258 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~4`~,; ~~ nt ~ u+nG~~~~~~~ ~ ~ T} -c ~. r, ~3FFICE v~F ~hE ~-`•ERIFF ~- FC C`=r;~c C~fV+~~j'~ ~kL.,-"iv~L..`' V~~ltiJl Y 1 i f ~.i ~iVJ t ~vr~{f1 Discover Bank vs. Case Number Kelly D Green 2010-4113 SHERIFF'S RETURN OF SERVICE 06/28/2010 09:22 PM -Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on June 28, 2010 at 2120 hours, he served a true copy of the within Complaint and Notice, u n the within named defendant, to wit: Kelly D. Green, by making known unto herself personally, at 141 treet, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same tir~l handi g t her personally the said true and correct copy of the same. ( ~ S SHERIFF COST: $39.70 June 29, 2010 SO ANSWERS, ~~ RON R ANDERSON, SHERIFF (cj County Suite Sheriff. T'eleosoft. h;c. FllrEt}-?`""1C ?7?? r t? , cF TH,. 1 5555 cu ? WU M IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: 10-4113 CIVIL TERM VS. PRAECIPE FOR DEFAULT JUDGMENT KELLY D GREEN Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 07887785 C A Pit DFO Judgment Amount $5353.19 4 I?-C)O PP Ai*r/ al 4474clHglo p,# 0109% IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 10-4113 CIVIL TERM KELLY D GREEN PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONTARY: Kindly enter Judgment against the Defendant KELLY D GREEN above named, in the default of an Answer, in the amount of $5353.19 computed as follows: Amount claimed in Complaint $4195.16 Less payments / adjustments made $0.00 Interest on the remaining principal balance of $4195.16 from October 09, 2009 to August 16, 2010 @ the interest rate of 28.990% per annum $1033.03 Attorney's fees $125.00 TOTAL $5353.19 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. W ro t,42524 07887785 A Pit DFO Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburgh, P 15219 And that the last known address of the De ndant is KELLY D GREEN 3 HILL ST MT HOLLY SPGS, PA 17065 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. KELLY D GREEN Civil Action No. 10-4113 CIVIL TERM NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that t e following Order of Judgment was entered against you on 918ljp (xx) Assumpsit Judgment in the amount of $5353.19 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 Pro By: - ----LIc KELLY D GREEN 3 HILL ST MT HOLLY SPGS, PA 17065 Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 Request for Military Status Department o f Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Aug-31-2010 11:20:54 Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency GREEN KELLY 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). 14 & Awt In A Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink.millfN//pis/PC09SLDR.htm1. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.dmdc.osd.mil/appj/scra/popreport.do 8/31/2010 Request for Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:SN3KFIRQTL https://www.dmdc.osd.mil/appj/scra/popreport.do 8/31/2010 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 10-4113 CIVIL TERM KELLY D GREEN 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 , KELLY D GREEN is not in military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMSC), which states that the DMDC does not possess any information indicating the individual status. KELLY D GREEN 3 HILL ST MT HOLLY SPGS, PA 17065 is not in the military service. Further Affiant sayeth naught. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. KELLY D GREEN Defendant Case No. 10-4113 CIVIL TERM IMPORTANT NOTICE TO: KELLY D GREEN 3 HILL ST MT HOLLY SPGS, PA 17065 Date of Notice: :1 la I 1 0 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU 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, WEINBERG & REIS CO., L.P.A. By: i l/ 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 7887785 A PIT H4N SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff . , E'?l i ; Jody S Smith Chief Deputy 231) FEB -8 ASf4 o' Richard W Stewart Solicitor `UMBULAND, cip-6- °.: PENNSYlyAh I Discover Bank Case Number vs. Kelly D Green 2010-4113 SHERIFF'S RETURN OF SERVICE 02/02/2011 10:13 AM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on February 2, 2011 at 1012 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Kelly D. Green, in the hands, possession, or control of the within named garnishee, M & T Bank, 1 W High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Vanessa Cassel, Teller, personally three copies of interrogatories together with three true an( 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 February 3, 2011 to Kelly D. Green at 3 Hill Street, Mt. Holly Springs, PA 17065. SO ANSWERS, "'r" ?.22 4'?' 'X Zz/? February 03, 2011 RON R ANDERSON, SHERIFF t o y R. Black, Deputy 1r r ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL - CIVIL DIVISION ?co -n r n rYz :: DISCOVER BANK r C} t ? Plaintiff No. 10-4113 CIVIL TERM csm S?Z%1 to 41 vs. INTERR GA TORIES IN ATTACHMAN1[-n M&T BANK KELLY D GREEN Defendant and M&T BANK 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 1.5219 (412) 434-7955 WWR#7887785 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No.: 10-4113 CIVIL TERM KELLY D GREEN Defendant and M&T BANK Garnishee TO: M&T BANK Suggested Reference No.: XXX-XX-2532 631 Holly Pike Mount Holly Springs, PA 17065 RE: KELLY D GREEN 3 HILL ST MT. HOLLY SPRINGS, PA 17065 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. G 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 savings accounts and certificates of deposit)? . 1 a. 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. 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. ?? \ \\P 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? 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? M\) 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? 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. f? 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 ftmds 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. § 81237 If so, identify each account. \? \ f?-A 9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these interrogatories on this institution. 10. If the answer to Interrogatory l 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? 12. If the response to Interrogatory I 1 is in the affirmative, state the amount of non-exempt funds on deposit in the account. \AJ FED, Q a 2?1? 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 W WR#7887785 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 ip* - (Name) LADV? of (Company) garnishee herein, (Title) 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. (SIGNATURE) WELTMAN, WEINBERG & REIS CO., L.P.A. BY: James C Warmbrodt, Esquire Attorney for Plaintiff(s) I.D. No.42524 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 7887785 DISCOVER BANK vs. KELLY D GREEN and M&T BANK Garnishee(s) Cumberland County Court of Common Pleas NO. 10-4113 CIVIL TERM PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: f? w? 70 ? C) Kindly marked the above matter discontinued and ended as to Garnishee(s), M&T BANK, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By Sworn to and subscribed Before me the /L day of February, 2011 NOTARY PUBLIC Jam -Notarial5eal Sheila G. Bevan, Notary Public Ross Twp., Allegheny county r... -ieelM ihmlres Nov. 15, 2014 armbrodt, Esquire r Plaintiff ? 0 -?414jef'6 3 7 lulf? vi5?53 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson FILED-OFFICE sF THE PRDTHONO 'AR ?, Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor QFF I RIFF 2011 SEE -2 PM 2: 35 CUMBERLAND CUUNT`z` PENNSYLVANIA Discover Bank vs. Kelly D Green Case Number 2010-4113 SHERIFF'S RETURN OF SERVICE 02/02/2011 10:13 AM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on February 2, 2011 at 1012 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Kelly D. Green, in the hands, possession, or control of the within named garnishee, M & T Bank, 1 W High Street, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Vanessa Cassel, 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. The writ of execution and notice to defendant was mailed on February 3, 2011 to Kelly D. Green at 3 Hill Street, Mt. Holly Springs, PA 17065. 09/01/2011 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: $87.05 SO ANSWERS, September 01, 2011 RON R ANDERSON, SHERIFF %c) Goun`,9ui!e Shenft. Te eos:;ft trr; IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 10-4113 CIVIL TERM vs. PRAECIPE FOR WRIT OF EXECUTION r� it (BANK ATTACHMENT ONLY) KELLY D GREEN.l 3 lei(1 at • "Spv n , 1, pat S Defendant(s) WOODFOREST NATIONAL BANK (pu 101 kVd � � / 703 Garnishees) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG& REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 Yt �) 3 C -mfr WWR No. 7887785 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 10-4113 CIVIL TERM KELLY D GREEN Defendant(s) WOODFOREST NATIONAL BANK 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 KELLY D GREEN , Defendant 3. against WOODFOREST NATIONAL BANK, , , Garnishee 4. Judgment Amount $ $5,353.19 Less Payments/credits received $ $0.00 Interest $ $1,063.90 Costs $ SUBTOTAL: $ $6,417.09 Costs(to be added by Prothonotary): $ WELTMAN, WEINBERG & REIS CO., L.P.A. By: " - . / William T. olczan, E ire 4a4.66 'J PA I.D. #47437 WELTMAN, WEIN: RG& REIS CO., L.P.A. 29. 7 C_R‘43Y 1400 Koppers Building 81) o c I t 11 436 Seventh Avenue Pittsburgh, PA 15219 01 tk (412)434-7955 L . So " ' C.K. /PH381 I WWR No. 7887785 .R.44 3cs73y6 v " O b T1SLec ' WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 10-4113 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff(s) From KELLY D.GREEN,3 HILL STREET,MT.HOLLY SPRINGS,PA 17065 (1) You are directed to levy upon the property of the defendant(s)and to sell You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEE(S)as follows: WOODFOREST NATIONAL BANK,60 NOBLE BLVD.,CARLISLE,PA 17013 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; (2) 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$5,353.19 Plaintiff Paid$ Interest$1,063.90 Attorney's Comm. % Law Library$ Attorney Paid$294.25 Due Prothonotary$2.25 Other Costs$ Date: JANUARY 21,2014 �� ` � _ David D.Buell,Prothonotary �i�/ _ Deputy REQUESTING PARTY: Name : WILLIAM T.MOLCZAN, ESQUIRE Address: WELTMAN,WEINBERG& REIS CO.,L.P.A. 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH,PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 47437 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson iLE - IC� F Sheriff Jody S Smith ,�>, ` Chief Deputy �{�� , � 218 � � Richard W Stewart Solicitors rf _ "� L � or- Discover Bank vs. Case Number Kelly D Green 2010-4113 SHERIFF'S RETURN OF SERVICE 01/24/2014 01:58 PM -Shawn Gutshall, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Woodforest National Bank, 60 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Brittany Barrett, Retail Banker, 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 January 27, 2014 to Kelly D. Green at 3 Hill Street, Mt. Holly Springs, PA 17065. SPIAM GUTSHALL, DEPUTY SO ANSWERS, January 27, 2014 RbNW R ANDERSON, SHERIFF {ci CountyGuite Sheriff,Teleosoft,Inc. y . ),chco'e, b Vs geill U.i tt,v\ u 10 -Li !1, , INTERROGAT1iRIES 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 savings accounts and certificates of deposit)? \Ir5 la. If the answer to Interrogatory I 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. (2^) AMIA,045 4ataAttf) o dvAaIA-a utvt 4 t9 v a s fll Y-O ` 4 P-e- 6t at -b Sf&J tro a,cGa,c,, s 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. Mo c, 3. At the time you were served or at any subsequent time did you hold legal title to ari pro rty of any nature owned solely or part by the defendant or in which defendant held or claimed any interest?r 4. At the time you were served or at any subsequent time did you hold as fiduciary ,pro rty ill-1,- which the defendant had an interest? cp •, /° 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? 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 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. • WWR No. 7887785 L I K5. /3 ),��►,g�P r'�A - V L)• fO t- 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. § 8123?If so,identify each account. a . J 9. If the answer to Interrogatory 1 is in the affirmative,state the date the sheriff served these interrogatories on this institution. _21+ 'LP 10. If the answer to Interrogatory I 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. 11l,0 .( 4 CI--(4-L '�01/eAdA40.41( S J, 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? NV/A, 12. If the response to Interrogatory 11 is in the affirmative,state the amount of non-exempt funds on deposit in the account. WELTMAN,WEINBERG&REIS CO.,L.P.A. By: 4/.;��''1 y• William T.Molczan, Es ire PA I.D. #47437 WELTMAN,WEINBERG& REIS CO.,L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh,PA 15219 (412)434-7955 WWR No.7887785 A 1 • x832.2.. LI I( v/ 0/1021.#"e OetAkit- Ktee,16 knat* 1,V ""`rt / VERIFICATION The undersigned does hereby verify subject to the penalties gfdalsI AFC.S. 4904 relating LEGAL DEPARTMENT 832-272B98 PH to unsworn falsifications to authorities,that he/she ism 375071 3 ,,tt.' n . _ Jame) L Cb4 of I/ bO 1 I i t 1` 14`lc ishee 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. DORIS NEFF LEGAL DEPARTMENT turAYA !• 832375-2898 PH 832.3753071 FAX Woodforest ti• Legal Dept 25231 Grogans MITI Rd., Suite 100 The Woodlands,TX 77380 832-375-2898 PH 832-375-3071 FAX WWR No. 7887785 la> YgLIKc- 3 t . r WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 10-4113 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt,interest and costs due DISCOVER BANK Plaintiff(s) From KELLY D.GREEN,3 HILL STREET,MT.HOLLY SPRINGS,PA 17065 (1) You are directed to levy upon the property of the defendant(s)and to sell You are also directed to attach the property of the defendant(s)not levied upon in the possession of • GARNISHEE(S)as follows: WOODFOREST NATIONAL BANK,60 NOBLE BLVD.,CARLISLE,PA 17013 and to notify the garnishees)that: (a)an attachment has been issued;(b)the gamishee(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; (2) 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$5,353.19 Plaintiff Paid$ Interest$1,063.90 Attorney's Comm. % Law Library$ Attorney Paid$294.25 Due Prothonotary$2.25 Other Costs$ Date: JANUARY 21,2014 I*.1, David D.Buell,Prothonotary Deputy REQUESTING PARTY: Name: WILLIAM T.MOLCZAN,ESQUIRE Address:WELTMAN,WEINBERG&REIS CO.,L.P.A. 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH,PA 15219 Attorney for:PLAINTIFF Telephone:412-434-7955 Supreme Court ID No.47437 TRUE COPY FROM RECORD In T,:stiniony whereof,I hare unto set my hand oai of saic Cc rt at Cariis!e,Pa. s_IX!Y day of ,20)9 Prothonotary a ,IkACla1/2 WELTMAN,WEINBERG & REIS CO.,L.P.A. BY: Matthew D Urban, Esquire Attorney for Plaintiff(s)?fl pi MAR _7 p 414 I.D. No. 90963 436 Seventh Avenue, Suite 1400 CUMBERLAND COU i Pittsburgh, PA 15219 PENNSYLVANIA Phone: 412.434.7955 Fax: 412.434.7959 File# 7887785 DISCOVER BANK Cumberland County Court of Common Pleas vs. KELLY D GREEN NO. 10-4113 CIVIL TERM and M&T BANK Garnishee(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter discontinued and ended as to Garnishee(s), M&T BANK, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By Matthew D Urban, Esquire Attorney for Plaintiff $1. 5-0p,/ c //q 99i/ 43024v, Ronny R Anderson. Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY THE PROT,HONOI'\t 1.011AUG 29 PM 2:C2 CUMBERLAND COUNTY i PENNSYLVANIA ppFlf,`E of THESHEFIF Discover Bank vs. Case Number Kelly D Green 2010-4113 SHERIFF'S RETURN OF SERVICE 01/24/2014 01:58 PM - Shawn Gutshall, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Woodforest National Bank, 60 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Brittany Barrett, Retail Banker, 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 January 27, 2014 to Kelly D. Green at 3 Hill Street, Mt. Holly Springs, PA 17065. 08/27/2014 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: $88.25 SO ANSWERS, August 27, 2014 RON& R ANDERSON, SHERIFF (c'! CourtySuite Sherif,, Teleosoft, Inc. 977x/ r 3/ 042-6 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DISCOVER BANK VS. KELLY D GREEN PRAECIPE FOR APPEARANCE TO THE PROTHONOTARY: Please enter my appearance for DISCOVER BANK in the above case. Date: December 18, 2014 NO. 2010-4113 l Eltman, Eltman & Cooper, PC Firm 140 Broadway, 26th Fl Address New York, NY 10005