HomeMy WebLinkAbout10-4204
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()F THE PFr-. .NARY
1010 JUN 23 PM 3, 49
MEu ; , 4 C;0UNTY
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
THOMAS LEE LEONARD
Defendant
No : to - yaoq D'W'A Tefrn
COMPLAINT IN CIVIL ACTION
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
07887104 C A Pit EMR
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+Qa.oo PA ATry
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No
THOMAS LEE LEONARD
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 b 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. Defendant is adult individual(s) residing at the address listed
below:
THOMAS LEE LEONARD
537 S 3RD ST
LEMOYNE, PA 17043
3. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXX9692 .
4. Defendant made use of said credit card and has a current balance
due of $7157.42 , 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 111" andl
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 THOMAS LEE LEONARD individually , in the amount
of $7157.42 with interest at the rate of 28.99001 per annum from
October 09, 2009 plus attorneys' fees of $125.00 , and costs.
s
436 S
Pitts
(412)
FAX:
0788
This law firm is a debt collector att
our client and any information obtain
Wa ro ,42524
WEINBERG & REIS CO., L.P.A.
h Avenue, Suite 1400
PA 15219
-7955
338-7130
C A Pit EMR
hg to collect this debt for
11 be used for that purpose.'.
VIJ%1rre,14'VGtt ai,loi.4z lai,Iai•4z tnter Amount tnclosed Below
CARD
Payment Due Date $ '?H 4
October 21, 2009 Please make check payable to Discover Card.
Minimum payment due includes a past due
amount of $1,429.00.
22 SDSN6A01 0004195
THOMAS LEONARD
537 S 3RD ST
LEMOYNE PA 17043-2005
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 IIL1,Il,nr1 111111 11 111111
CAROL STREAM IL 60197-6103
Iill ulluIll 1Ill 111111111111,1111Ill 111111 Ill 1111111111111111
000001986458864303413071574200000000715742
Discover More Card Account Summary
Closing Date: September 22, 2009 page 1 of 1
Account number ending in 9692 Previous Balance
Payment Due Date October 21, 2009
Minimum Payment Due $7
157
42 Payments And Credits $7,157.42
0.00
,
.
Credit Limit
$6,000.00 Purchases 0.00
Cash Advances +
Credit Available $0.00 Balance Transfers + 0.00
Cash Credit Limit $0.00 Finance + 0.00
s
Cash Credit Available $0.00 + 000
New Balance lance
= $7,157.42
i
'Cashback Bonus® O
i
C
h
pen
ng
as
back Bonus Balance $ 0
00
.
New Cashback Bonus This Period + 0,00
-6ashbock-BonusSAnniversary - - - - Cashback Bonus Balance $ 0.00
ate: June 22
How Can We Help You? 1 • Visit Discover.com to pay your bill for no cost
view
our
It's your choice - 3 ways to hel ,
y
latest Account information, earn and redeem rewards and more
2
Call 1-800
DISCOVER
p
Please have your Discover Card available. .
-
(347-2683) for Fast, easy self-service
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
,
Sale Lake City, UT 84130
Transactions $0 Fraud Liability Guarantee Use
our Dis
C
d
y
cover
ar
with confidence.
j Information For You
Your Account is overlimit. While we are permitted under the
have chosen not to do so
t thi
ti Cardmember Agreement to charge you an Overlimit Fee
we
,
a
s
me. We reserve the right to do so if, as of the close of a billing period, your outstanding
Account balance exceeds your Account credit limit. See the Overlimit Fee section of th
C
d
e
ar
member Agreement for details.
i
EXHIBIT
I
Finance Charge Summary
Average Daily
Daily Periodic Nominal
ANNUAL ANNUAL Transaction
PERCENTAGE PERCENTAGE Periodic Fee
a a ees
Rates
current billing period: 22 days FINANCE
RATES PET FINANCE CHARGES
- C G
Purchases $0 0.07942%
Cash Advances $0 0.07942% 28.99% F 28.99%
$0 $0
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.
Important Information. If there is more than one page to this billing statement, see the back of each page for additional important information.
Cn
Bee your Cwdmember Agreement. Your Cardmember Agreement contains all the terms of your Account 0
Lost or stolen to rds. Report immediately. Call 1400-347-2683. Z
gory In Case of Errors or Questions About Vour Bill. If you think your bill is wrong, or if you need more information about a o
transacU on your DiIC wnte to us on a separate sheet of paper at Discover .Card; POBox 30421, Salt Lake City, UT 84130-0421, as soon as possible.
?
We must hear Trom you no later than 60 days after we sent you the Iirst bill on which the error or problem appeared. You can telephone us but °o
doing so will not preserve your rights In your fetter, give us the following mformaUon:
'Your name and Account number.
The dollar amount of the suspected error.
'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 x
about
You do not have to pay any amount in question while we are investigating, but you are still obligated to pay the pails of your bill that are not in
question. While we investigate your question, we cannot report you as delinquent or take any action to collect the amount you question.
vreW Rude for Credit Card Purchases: If u have a problem with the quality of goods or services that you purchased with a credit card, and
ybu =as have tried in good faith to correct the problem with the merchant, you maYy not have to pay the remaining amoundstate on r goods 00
You have this protection only when the purchase price was, more than S50 and the purc ase was made in your of your mailing address (If we own or operate the merchant, or if we mailed you the advertisement for the goods or services, all purchases are
covered regardless of the amount or location of purchase.)
Payments. Send only your payment and the top portion of this statement in the envelope provided. Do not send cash. By sending your check, as
described above, you authorize us to use information on your check to make an electronic fund transfer from your account at the financial institution
indicated on your check or to process the payment as a check transaction. If payment is processed as an electronic fund transfer, the transfer will
accoounthasasooon as the same day we eceiveyourfpayment, and you will not receive your check back frromayourrfinancialiinstittuutionhdrawn from your
The processing of your payment mabe delayed if You send cash correspondence or other items with your ppayment if you send the payment to any
other address or it ru use an envelope other than a one provided. Payments received on or after 1 PM Monday throe h Fridaror-en- & ,weekend
or bank holiday will ? posted to your Account as of the next business day. If you have misplaced your envelope send your payment to Discover
Bank, PO Box 6103, Carol, Stream, IL 60197.6103. Please allow 7-10 days for delivery. if your payment is returned unpaid, we reserve the right to
resubmit it as an electronic debit
You can pay your minimum payment or a greater amount over the telephone, and you can set up automatic payments Call us at 1-800-347-2683.
You will need this statement and your bank account information. You must ensure that sufficient funds are available in your bank account and all
transactions must comply with U.S. law. You will be asked to provide the first 5 digits of your account statement zip code, By entering those
numbers as your electronic signature, you will be agreeing to this authorization to allow us and your bank to deduct each payment you authorize
from your bank account and to initiate debit or credit entries to your bank account, as applicable to correct an error in the processing of such
payment You must tell us the amount of each payment or you can select an amount such as the Minimum Payment Due or the New Balance on
each statement You can cancel a payment however we must receive notice at least three gbusiness days in advance of the scheduled payment You
may Y on teach monthly statement when your payment wiladdress bde and howpmucihuit will be ph Your Automatic payment amount may be lass .lthan
indicated on the monthly statement based on credits or payments applied during the billing cycle.
Credit Reporting. We may report information about your account to credit bureaus. Late payments, missed pa ents, or other defaults on your
account maY be reflected in your credit report We normally report the status and pacent history of your Account to credit reporting agencies each
month. If Nu believe that our report is inaccurate or incomplete please write us at tfie following address. Discover Card, PO Box 15316, Wilmington,
DE 19850-5316. Please include your name, address, home telephone number and Account number.
PERIODIC FINANCE CHARGES. Periodic Finance Charges are imposed on all transactions from the date the transaction is posted to your Account
until the date you pan your entire New Balance, by making payments or receivingg credits. However, it you paid the New Balance on your previous
billing statement. by the Payment Due Date shown on that statement and you paylhe New Balance by the Payment Due Date on your Current billing
statement we will not impose Periodic Finance Charges on new purchases that is, purchases first appearing on the current statement We call this
the grace period. Otherwise, you will receive a billing statement next month that includes Periodic appearing Charges on those new purchases. There
is no grace period on balance transfers or cash advances.
We sort your transactions into groups of purchases cash advances, and balance transfers and then further sort the transactions within each group by
their Annual Percentage Rate. For example, purchases subject to a promotional rate and purchases subject to a standard rate would be separate
groups. We refer to these groups as transaction categories. At the end of each billing period, we compute balances and Periodic Finance Charges
for each day of the billing period for each transaction category. We use the following equation to compute Periodic Finance Charges for each
transaction category. Average Daily Balance x number of days in the billing? period xi Daily Periodic Rate. (You may refer to the finance Charge
summaryon your billing statement Tor these amounts.) Then we add up i"i3eriodic Fnance Charges for eac transaction category to get the total
Periodic Finance Charges for your Account The Average Daily Balance is shown as zero if, because of the grace period, no Perio?ic Finance Charges
apply to the balance in a transaction category.
We use the two-cycle daily average balance (including new transactions) method of calculating the balance upon which we impose Periodic Finance
Charges. This means if you did not pay the New Balance shown on the billing statement 9bu received. duringg the previous billing period by the
Payment Due Date shown on that statement we will impose Periodic Finance Charges on new purchases that firs i appeared on that billing statement
as well as new purchases that first appear on the current billing statement unless we already imposed Periodic Finance Charges on the purchases on
your previous billing statement
We compute the Average Daily Balance for each transaction cate orry/ b adding ug all the dairy balances in a billing period for a transaction categgorryy
and. dividingg the total by the number of days in the billing cycle. We compute the daily balance for each transaction, category on each day by first
adding theTollowing to the previous days daily balance: transactions made that day, fees charged that day and Penodic Finance Charges accrued
on the previous days daily bala nce; and by then subtracting any credits and payments that are applied against the balance of the transaction
category on that day. In calculating the dairy balance for the first day of the billing period, we consider the ' previous days balance" to have been
your balance for each transaction category on the last day of your previous billing period. If a transaction is posted to your Account after the close
of the billing period in which it occurs, we will treat the transaction as having occurred on the first day of the billing period in which it is posted to
your Account T ansaction Fee
fees
are aooeo w me ap UL
balance transfer an tt
rate has been terminate
Finance Charges in the
we leave
until the
the
of Cash Advance r
we tmove the unpaid bCha alance ofhthe
n category. However, if the special
he Balance Transfer Transaction Fee
May-24, 2010 8:23AM
No, 2030 P. 23
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA.C.S. 14904 relating
to unsworn falsifications to authorities, that he/she is
ACCOUNT MANAGER of DFS SERVICES LLC (Nam
(Title) plaintiff herein, that
(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.
ig ure)
WWR# 7887104
DFS# 6011002770289692
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny RAnderson ~E, Fyn 4,_ _I,,,,~
Sheriff T
p~ti5~lr o1' ~Tlrrr,~p~,~r ~`!r I~lr J ~ ~ ~~,I~7't`sf?'f
Jody S Smith ~ ~'o ~'l
Chief Deputy ~~. ~ ~~ ~ ~ ~~~ _~ ~: ~ ~
Richard W Stewart '~~ ` ~~
Solicitor ~~I~.~ aF -F<~ ~.,~r;;i~F CU~i~L: :. .~''.Jf~i~
Discover Bank
vs. Case Number
Thomas L. Leonard 2010-4204
SHERIFF'S RETURN OF SERVICE
07/02/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search
and inquiry for the within named defendant to wit: Thomas L. Leonard, but was unable to locate him in his
bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Thomas
L. Leonard. Request for service at 537 S. 3rd Street, Lemoyne, PA 17043 is vacant. The Lemoyne
Postmaster has advised, Thomas L. Leonard had forwarded his mail to 717 Market Street #396,
Lemoyne, PA 17043. However, the UPS Store at this address advised Deputies, Thomas L. Leonard no
longer has a P.O. BOX at this location.
SHERIFF COST: $47.40
July 02, 2010
SO ANSWERS,
RON R ANDERSON, SHERIFF
~cl CountySuile Shenff. Teleosoft. Inc.
Fl"E0-O FicE
G TV'E pROTHOHOTAR'`(
2Utt JAt??t P?1 2? ??CllMQ$ENNSYLVA'N'A?T
,
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
THOMAS LEE LEONARD
Defendant(s)
No. 10-4204 CIVIL TERM
PRAECIPE TO REINSTATE COMPLAINT
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
Benjamin R Bibler, Esquire
PA ID #93598
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Buidling
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#7887104 DIS
ca 5o0 V80(p
gA)5y 0
r,
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No. 10-4204 CIVIL TERM
THOMAS LEE LEONARD
Defendant(s)
PRAECIPE TO REINSTATE COMPLAINT
Kindly reinstate the Complaint in the above captioned matter.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By: JA,'
/-
Benjamin squire
PA ID #9 5
WELTMA , WEINBERG & REIS CO., L.P.A.
1400 Koppers Buidling
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR #7887104
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny RAnderson -r] L 0-0FF1
Sheriff ??r T?4 , .
;,
Jody S Smith
Chief Deputy -
E 1 FEB -8 P 3' 0
Richard W Stewart J Es L '. 'j T
Solicitor - ?! y mrF? l j -
Discover Bank
vs. Case Number
Thomas Lee Leonard 2010-4204
SHERIFF'S RETURN OF SERVICE
02/01/2011 02:46 PM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on
February 1, 2011 at 1446 hours, she served a true copy of the within Complaint and Notice, upon the
within named defendant, to wit: Thomas Lee Leonard, by making known unto Han Leonard, Mother of
defendant at 112 Sharon Road, Enola, Cumberland County, Penns ylvani 17025 its contents and at the
same time handing to him personally the said true and correct copy oft e 77,41
MI HELLE GUTSHALL, DEPUTY
SHERIFF COST: $55.90
February 02, 2011
SO ANSWERS,
RONNY R ANDERSON, SHERIFF
DISCOVER BANK
Plaintiff
vs.
THOMAS LEE LEONARD
TO THE PROTHONTARY:
FILED-CFFIC4
IN THE COURT OF COMMON PLEA?F THE PROTHON6-'AIRY
CUMBERLAND COUNTY, PENNSYLVANT
CIVIL DIVISION ?u?? MAR 2$ PM is n
CUMBERLAND COUNTY
PENNSYLVANIA
Civil Action No. 10-4204 CIVIL TERM
PRAECIPE FOR DEFAULT JUDGMENT
Kindly enter Judgment against the Defendant THOMAS LEE LEONARD above
named, in the default of an Answer, in the amount of $10240.65 computed as
follows:
Amount claimed in Complaint $7157.42
Less payments / adjustments made $0.00
Interest on the remaining principal balance of
$7157.42 from October 09, 2009 to March 15, 2011
Q the interest rate of 28.990%s per annum $2958.23
Attorney's fees $125.00
TOTAL $10240.65
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. Wdokmbrodt,42524
07887104 (71A Pit DFO
Plaintiff's address is:
c/o WELTMAN, WEINBERG & REIS CO., L.P.A.,
436 Seventh Avenue, Suite 1400 Pittsburgl
And that the last known address of the
THOMAS LEE LEONARD
112 SHARON RD
ENOLA, PA 17025
A 15219
t is .
fl
l`,?!tf 6/e l/i/k
9? 7/7e
I k,--
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs,
THOMAS LEE LEONARD
Defendant
Case No. 10-4204 CIVIL TERM
IMPORTANT NOTICE
TO:
THOMAS LEE LEONARD
112 SHARON RD
ENOLA, PA 17025 ?t
Date of Notice:
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) 248-3166
WELTMAN, WEINBERG & REIS CO., L.P.A.
Matthew Urban
P.A.1.D.# 90963
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue, 1400 Koppers Building
Pittsburgh, PA 15219
Phone: (412) 434-7955
7887104 A PIT B41
r
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS.
THOMAS LEE LEONARD
Civil Action No. 10-4204 CIVIL TERM
NON-MILITARY AFFIDAVIT
The undersigned is the duly authorized agent and/or attorney for the
Plaintiff in the within matter and states as follows:
Affiant 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 , THOMAS LEE LEONARD is not in military service.
Affiant further states that this belief is supported by the attached
certificate from the Defense Manpower Data Center (DMDC), which states that
the DMDC does not possess any information indicating that the below
individual is in the military service:
THOMAS LEE LEONARD
112 SHARON RD
ENOLA, PA 17025
Affiant further states that the averments contained herein are true and
correct to the best of Affiant's knowledge, information and belief and that
these averments are made subject to the penalties of 18 Pa C.S.A. Section
4904 relating to unsworn falsification to authorities.
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
Mar-15-2011 07:25:14
-[ Last
Name First/Middle Begin Date Active Duty Status Active Duty End Date Service
Agency
LEONARD THOMAS Based on the information you have furnished, the DMDC does not possess
LEE 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 htti)://www.defenselink.mil/fag/l)is/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 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 3/15/2011
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:63PSB9GL01
https://www.dmdc.osd.mil/appj/scra/popreport.do 3/15/2011
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No. 10-4204 CIVIL TERM
THOMAS LEE LEONARD
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 ?LUII
(xx) Assumpsit Judgment in the amount of $10240.65 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
Prothonota
By: z
PROTHONOTARY
THOMAS LEE LEONARD
112 SHARON RD
ENOLA, PA 17025
Plaintiff's address is:
c/o WELTMAN, WEINBERG & REIS CO., L.P.A.,
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434-7955
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iN HE COUNT OF COMMON 21,EA' OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL 141`'.'ISION
DISCOVER FLANK
Plaintiff
vs. C' -i1 Action No. 10-4204 CIVIL TERM, ,
THOMAS I LE LEONARD
Defendant(s) VU1el p1A as =M
SUSQUEHANNA BANK
1? f
Garnishee(s) C+ `tAC l
PRAECIPE FOR WRIT OF EXECUTION =CD X"r
TO THE PROTHONOTARY: = -'
Kindly issue a Writ of Execution in the above matter...
1. directed to the S;+eriff of CUMBERLAND County:
2. against T! JOMAS LEE LEONARD , Defendant
against St.;SQLIEHt:NNA B?tNK , , GE:-n'shee
?'. Judgrnent::mount $ $10,240.65
Less Pa--worts/credits received $ $0.00
Int:e? Est $ $343.41
Cost. $
SUBTOTA i •• $ $10,584.06
Costs (to +6e added by Prothonotary): $
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WELTMAN, WEINBERG & R)2-!S CO., L.P.A.
By: _1?/
William . Molczan, Esquire
PA LD.447437
WELTMAN, W,',INBERG & REIS CO., L.P.A.
1400 Koppers Buiiding
135 Seven h Avenuc
"i ,sburgh, PA 152 19
4 , 2) 434 `955
1 WWR No. 7857104
af 61C
WRIT OF EXECUTION and/or ATTACHMENT
% avid D. Buell, Prothonotary
(Seal) By:
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
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 10-4204 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s)
From THOMAS LEE LEONARD, 112 SHARON ROAD, ENOLA, PA 17025
(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
GARNISHF;E(S) as follows:
SUSQUEHANNA BANK, 1196 WALNUT BOTTOM ROAD, 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;
(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$10,240.65 L.L. $.50
Interest $343.41
Atty's Comm % Due Prothy $2.00
Atty Paid $246.30 Other Costs
Plaintiff Paid
Date: OCTOBER 31, 2011
Ira THE COURT OF COMMON PLFAS C1_,'N1BERLAND COUNTY, PENNSYLVANIA
C1 /IL DI \'ISION
DISCOVER BANK
Plaintiff
vs.
THOMAS LEI; LEONARD
Defendant(s)
SUSQUEHANNA Bf\NK
Garnishee(s)
Civil Action No. 10-4204 CIVIL TERM
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10: S'_'S( _UEHAN` NA BANK, 1196 WAI,NU f BO'l-TON RD, CARLISLE, PA 17013
RE: THON4AS LYE LFONARD, 112 SS iARON RD, LNOLA. PA ' 7025
Suggested X,_;f,-rencc No.: XXX-XX-5154
XXX-XX. '.s?`` S
IMPORTANT NOTICES 0 GAlUNTSHEE!
A Yo;, are required to file answers to the following interrogatories within twenty (20) days after
service upon you. Failure tc d-, so aav result in Judgment against you.
B. Here 'in, trte word "defendant" means any one or more of the defendants against whom the writ of
Execution is issued.
C1. While service of Writ upon the Garnishee attaches a;i property of the Defendant subject to
attachment wi;ich is then in the hands of the garnishee., it also attaches all property of the defendant which comes
into the Garuishee'? possession thereaf r, 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 ?udgment against the Garnishee, but rather by the amounts deposited
and withdrawn during the Intervening period,
WWR No. 7887104
ANSWERS TO INTERROGATORIES IN ATTACHMENT
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)?
No.
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 woe 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.
N/A
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.
No.
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 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 delivery 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 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 Pa.C.S. § 8123? If so, identify each account.
No.
9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these
interrogatories on this institution.
N/A
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.
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
VERIFICATION
I, Catherine M. Bush, verify that the facts set forth in these Garnishee's Answers to
Interrogatories are true and correct to the best of my knowledge, information, and belief. This
statement is made subject to the penalties of Section 4904 of the Crimes Code (18 PA.C.S. §
4904) related to unsworn falsification to authorities.
Dated: November 7, 2011
Catherine M. Bush,
Assistant Secretary and
Legal Counsel
Susquehanna Bank
26 North Cedar Street
Lititz, Pa 17543
(717) 625-6273
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
00', s? oC C11M11rp/,r"4
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- THE PROTNONO TA,,
ZOI I NGV 2 I AM 10: c6
11MBERLAND CoUN r
PE)gNS YLVANIA
Discover Bank
vs.
Thomas Lee Leonard
Case Number
2010-4204
SHERIFF'S RETURN OF SERVICE
11/04/2011 03:20 PM - Amanda Cobaugh, 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, Susquehanna Bank at 1196 Walnut Bottom Road,
South Middleton Township, Carlisle, PA 17013, Cumberland County, by handing to TAMI MCKEE,
FINANCIAL SERVICE REP., personally 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 November 4, 2011 at Thomas Lee Leonard
at 112 Sharon Road, Enola, PA 17025.
11/17/2011 Ronny R Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is
returned STAYED, per request from plaintiff's attorney.
SHERIFF COST: $88.11 SO ANSWERS,,
November 17, 2011 RON R ANDERSON, SHERIFF
CQ v o?d c;,.
. sz) Z-z-,jad -
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AIV ?6,766 3
ic; Coun'ySuite Sheriff Te eo8ott 6?;:.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTI-1 OF PENNSYLVANIA)
COUN"1'Y OF CUMBERLAND)
NO 2010-4204 Civil
CIVIL ACTION -LAW
TO ~I•HE SHERIFF OF CUMBERLAND COUNTY:
'I•o satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s)
From THOMAS LEE LEONARD, 112 SHARON ROAD, ENOLA, PA ]7025
(I )Y'ou are directed to levy upon the property of the defendant (s)and to sell
(2j You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
CITIZENS BANK, 665 NORTH EAST STREET, 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 fi-om delivering any property of the defendant
(s) or otherwise disposing thereof;
(~) 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 Due510,240.65
Interest $824.87
Attv's Comm
Atty Paid $358.91
Plaintiff Paid
Date: AUGUST 13, 2012
rSeal)
L.L. $
Due Prothy 52.25
Other Costs
i
David D. Buell, Prothonotary
Deputy `-
REQUES'I'I~NG PAnTY:
Name :MATTHEW H. URBAN, ESQUIRE
Address: V1'EI.TMAN, WEINBERG & REIS CO., L.P.A.
1400 KOPPERS BUILDING
436 SEVENTH AVENUE
PITTSBURGH, PA ]5219
Attorney for: PLAINTIFF
Telephone: 412-434-7955
Supreme Court ID No. 90963
1N THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff ~ c
vs _.~ ~
Civil Action No. 10-4204 CIVIL TE
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THOMAS LEE LEONARD 17613 tom .
Defendant(s) ~~k ~ /~ l~s~e ~ j7f}-
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CITIZENS BANK `q~p S ~VcX~^ ~ ~
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Garnishee(s)
PRAECIPE FOR WRIT OF EXECUTION
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TO THE PROTHONOTARY:
Kindly issue a Writ of Execution in the above matter...
1. directed to the Sheriff of CUMBERLAND County:
2. against THOMAS LEE LEONARD ,Defendant
3. against CITIZENS BANK, , ,Garnishee
4. Judgment Amount $ $10,240.65
Less Payments/credits received $ $0.00
Interest $ $824.87
Costs $
SUBTOTAL: $ $11,065.52
Costs (to be added by Prothonotary):
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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
a ~ s ~Il'e loo.
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WWR No. 7887104
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
THOMAS LEE LEONARD
Defendant(s)
CITIZENS BANK
Garnishee(s)
No. 10-4204 CIVIL TERM
P ~ E FOR „~'~~CUTION
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
Matthew D. Urban, Esquire
PA I.D. #90963
WELTMAN, WEINBERG & RF,IS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412)434-7955
WWR No. 7887104
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
a d'? ?Ft3t?iJ
v
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
Discover Bank
vs.
Thomas Lee Leonard
2 t,U G 22 A QW: I
PEW4SYL'IAN M
Case Number
2010-4204
SHERIFF'S RETURN OF SERVICE
08/17/2012 11:09 AM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on August
17, 2012 at 1109 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and
monies of the within named defendant, to wit: thomas Lee Leonard, in the hands, possession, or control of
the within named garnishee, Citizens Bank, 665 N East Street, Carlisle, Cumberland County,
Pennsylvania 17013, by handing to Tabitha Startzman, 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 08-21-12 to Thomas Lee Leonard at 112
Sharon Road, Enola, PA 17025.
SO ANSWERS,
August 21, 2012 RON R ANDERSON, SHERIFF
uth al, Deputy
(C) %OurtyS lte; Shen f, I elno5nTt, InC
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
,)nny R Anderson i~,LED_OFF ICL
Sheriff I'I€ 1:} t
�Qt�lrtr o1 �:.rrrntrr��� � ��� �� T���� IA
Jody S Smith
Chief Deputy 281 AR' 18 PM 2: 35
Richard W Stewart
Solicitor QPFtCEOF THE SfiERIFF CUMBERLAND COUNTY
PENNSYLVANIA
Discover Bank
Case Number
vs.
Thomas Lee Leonard 2010-4204
SHERIFF'S RETURN OF SERVICE
08/17/2012 11:09 AM-Shawn Gutshall, Deputy Sheriff,who being duly sworn according to law, states that on August
17, 2012 at 1109 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and
monies of the within named defendant,to wit:thomas Lee Leonard, in the hands, possession, or control
of the within named garnishee, Citizens Bank,665 N East Street, Carlisle, Cumberland County,
Pennsylvania 17013, by handing to Tabitha Startzman,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 08-21-12 to Thomas Lee Leonard at 112
Sharon Road, Enola, PA 17025.
03/18/2013 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: $87.42 SO ANSWERS,
March 18, 2013 R-ONIV R ANDERSON, SHERIFF
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(c)CounrySuite Sheriff.Teleosoft,b.c.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
DISCOVER BANK
VS. NO.
THOMAS LEE LEONARD
PRAECIPE FOR APPEARANCE
TO THE PROTHONOTARY:
Please enter my appearance for DISCOVER BANK
in the above case.
Date: December 18, 2014
2010-4204
Stephen Selinger
Print Name
Eltman, Eltman & Cooper, PC
Firm
140 Broadway, 26th Fl
Address
New York, NY 10005