HomeMy WebLinkAbout10-4624T a
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS.
JENNIE D CARSWELL
Defendant
No: l0 - a-tyi I Ism
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
08388988 C A Pit EMR
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No
JENNIE D CARSWELL
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 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:
JENNIE D CARSWELL
32 S ENOLA DR
ENOLA, PA 17025
3. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXX8916
4. Defendant made use of said credit card and has a current balance
due of $2512.94 , as of May 05, 2010
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 May 05, 2010 . A copy of
Plaintiff's Statement is attached hereto, marked as Exhibit 11111 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 , JENNIE D CARSWELL individually , in the amount of
$2512.94 with interest at the rate of 28.9900 per annum from May 05,
2010 plus attorneys' fees of $125.00 , and costs.
James C Wa ro t,42524
WELT , WEINBERG & REIS CO., L.P.A.
436 Se e th Avenue, Suite 1400
Pitts r PA 15219
(412) 431-7955
FAX: 41 338-7130
0838 98,8 C A Pit EMR
This law firm is a debt collector attemft/ng to collect this debt for
our client and any information obtained ill be used for that purpose.
DISCOVER New Balance Minimum Payment Due
$2,512.94 $2,512.94
08 SDSN6A01 0003181
JENNIE CARSWELL
32 S ENOLA DR
ENOLA PA 17025-2704
Payment Due Date
DUE VAMEDIATELY
Account Number ending in 8916
Enter Amount Enclosed Below
$1
Go papeiiess and make your account
Information more secure with password-
statalmrlts any you can access.
care more at discovercornfpaperless.
PO BOX 6103 111111111 111111611
CAROL STREAM IL 60197-6103
Address, e-mail or telephonechangeY
Go to www.Discover corre ar print Chong* in space above 1r11rr11mnr111r1 If I III ??iluur1111rrur11i??ur n11u1n11
.
000001986458327978363025129400000000251294
'Opening Date: April 1, 2010 - Closing Date:
D-tscover More Card Account Summary
Cardenember since
Account number ending in 8916
Previous Balance $2,512.94
Payments And Credits 0.00
Purchases + 0.00
Balance Transfer + 0.00
Cash Advances + 0.00
Finance Charges + 0.00
Other Fees t + 0.00
New Balance 2,512.9
See Finance Charge Summary section Following transactions
for detailed APR information
Credit Line $1,900.00
Credit LineAvoilabkr --------- -- - --------50:00-
Cash Advance Credit Line $0.00
Cash Advance Credit Line Available $0.00
6, 2010
e ea e
Payment Information
New Bakeries $2,512.94
Minimum Payment Due* $2,512.94
Payment Due Date DUE IMMEDIATELY
*Includes past due amount of $489.00
Lob Paysrwel Waning: If we do not receive your minimum
payment by the dab listed above, you may have to pay a kale
fee of up to $39.00.
Mininwn Payment Warning: If you make only the minimum
payment each period, you will pay mom in interest and it will
take you longer to pay off your balance. For example:
I Only the minimum I 8 recent I $2,513 I
PaYm" t See transaction detail for a description of any lees
Anniversary Month
October
If you would like infatuation about credit counseling services,
call 1.800.347.1121.
Opening Cashbock Bonus Balance $ 0.00
New Cashbock Bonus This Period + 0,00
Cashbadc Bonus tlalaea $ 0.00
To Isom mars, log in a www.Diteover sore and select Rewards
EXHIBIT
3 Easy Ways to Contact Us Manage Your Account Online at vwvwDiscover.com
1. Acceu your account securely at vwvw.D6cover cam • Access Gee online tools like Paydown Planner to create a plan
2. Call 1.800-DISCOVER (1.800.347.2683 to pay down your balance, sae ocean dater, ,
Please have your Diuovereeard avaiksk>?, bills online and easily hack all kaaoetions f?Y
3. Write to w at Discover, PO Box 30943, Make your money worth moresm-find easy to some
---Salt aks-City,UTE4130---- _--.--------- ----and•redaam?os. i9wads -- ---- ways; s to
TDD (Telecommunications Device for the Deaf) NEWT Acccc » your account securely through your
assistance, please call 1-804347-7449, mobile
'Transactions
8388988 D? Defies
,Finance Charge Summary
N
r Al er
Average
Dail Daily
P
i
di AN
U
PERCENTAGE ANNUAL
PE P odic w
y
current billing period: 8 days 13alan<a er
o
c
Rates
RATES RCENTAGE
RATES
CHARGES FINANCE
CHARGES
'Purchases $O 0.07942% 28.99% 28.99X. $0 $0
Cash Advances so 0.07942% 28.99% 28.99% $O s0
V . Variable Rate
See revene side. DISCOVER
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 James Ball
(Name)
Team Leader 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 knowledge, information and belief.
WWR# 8388988
Jennie D. Carswell
1 1 916
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Sheriff ~ ~'-~= ~ ; F~, ~,
Jody S Smith ,~a„atr at ~ua9bcrl,~~,~ ,,t ~' ;' _ ; ~ ..,, r
Chief Deputy G . `_ ' `'
Richard W Stewart .~'`.~,~~ a0~~ ~UCT 1 d ~'
Solicitor oFFicls ~ F Ttia aH_RiFF + r , ~ '.~~~
Ronny R Anderson
Discover Bank
vs. ' Case Number
Jennie D. Carswell 2010-4624
SH~RIFF'S RETURN OF SERVICE
07/16/2010 06:50 PM -Shawn Harrison, eputy Sheriff, who being duly sworn according to law, states that on July 16
2010 at 1850 hours, he serv a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Jennie D. arswell, by making known unto herself pe ovally, 32 S. Enola Drive,
Enola, Cumberland County nnsylvania 17025 its contents and at th me ti a anding to her
personally the said true and c rrect copy of the same. n
,DEPUTY
SHERIFF COST: $41.50
July 19, 2010
SO ANSWERS, f~/J//ry
RON R ANDERSON, SHERIFF
(cJ CountySuite Sheriff. Teleosoft, Inc.
.r
~~~ T~-~ ~'nOTNONOTAR't'
~~I~I ~~T ?2 ~M 9~ 34
^!.'~~~R~.A~D C~UPdTY
EP~SYLVA~IA
DISCOVER BANK
Plaintiff
vs.
JENNIE D CARSWELL
Defendant
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
No: 10-4624 CIVIL TERM
PRAECIPE FOR DEFAULT JUDGMENT
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
08388988 C A Pit ALL
Judgment Amount $2502.39
~ I~}.o0 PO A~'M
C~ +~®x,3530
a50D (c (p
~~-(1CC Muwt~
7
DISCOVER BANK
Plaintiff
vs.
JENNIE D CARSWELL
TO THE PROTHONTARY:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Civil Action No. 10-4624 CIVIL TERM
PRAECIPE FOR DEFAULT JUDGMENT
Kindly enter Judgment against the Defendant JENNIE D CARSWELL above
named, in the default of an Answer, in the amount of $2502.39 computed as
follows:
Amount claimed in Complaint $2512.94
Less payments / adjustments made $421.00
Interest on the remaining principal balance of
$2225.44 from May 05, 2010 to October 14, 2010
@ the interest rate of 28.990 per annum $285.45
Attorney's fees $125.00
TOTAL $2502.39
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
t,42524
0838898~~C A Pit ALL
Plaintiff's address is:
c/o WELTMAN, WEINBERG & REIS CO., L.P.A ,
436 Seventh Avenue, Suite 1400 Pittsbur h, PA 15219
And that the last known address of the D fendant is
JENNIE D CARSWELL
32 S ENOLA DR
ENOLA, PA 17025
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs
JENNlE D CARSWELL
Defendant
Case No. 10-4fi24 CIVIL TERM
IMPORTANT NOTICE
TO:
JENNIE D CARSWELL
32 S ENOLA DR
ENOLA, PA 17025 nn
Date of Notice: ~ cX ~ ,
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 THi5 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 SERVIGES 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 ERG &REIS CO., L.P.A.
Y~
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
8388988 A PiT T4S
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
JENNIE D CARSWELL
Civil Action No. 10-4624 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 ioe
(xx) Assumpsit Judgment in the amount of $2502.39 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
Prothonot
By:
JENNIE D CARSWELL
32 S ENOLA DR
ENOLA, PA 17025
Plaintiff's address is:
cfo WELTMAN, WEINBERG & RETS CO., L.P.A.,
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434-7955
IN THE COMMON PLEAS COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
Civil Action No. 10-4624 CIVIL 'T'ERM
NON-MILITARY AFFIDAVIT
JENNIE D CARSWELL
Defendant
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, JENNIE D CARSWELL is not in the 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:
JENNIE D CARSWELL
32 S ENOLA DR
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. §4904 relating to unsworn falsification to authorities.
Request for Military Status
Department of Defense Manpower Data Center
4..,
4 -?i '~
Military Status Report
Pursuant to the Service Members Civil Relief Act
Page 1 of 2
Oct-18-2010 07:48: l 3
~ Last
Name First/Middle Begin Date Active Duty Status Active Duty End llate Service
Agency
CARSWELL JENNIE D 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 Ilealth, 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 http://www.defenselink.mil/faglpis/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 tJSC App. §521(c).
If you obtain additional information about the person (e.g., an SSN, improved accuracy ol~ 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.
httn~~//www rimrlc ncrl mil/annii~rra/nnmm~nrt can 1O/1 R/7(11(1
Request for Military Status Yage 2 of 2
More information on "Active Duty Status"
Active duty status as reported in this certificate is defined in accordance with 10 t1SC § 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. 'Phis
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 t1.S. Public 1-lcalth
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 SC:RA 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:2F7KNDLBNC
httn~•(lwww rlm~ir. n~ri mil/an»i/c~ra/nnnrennrt ran 1(1/1 R/~(11(1
ICE
IN THE COURT OF COMMON PLEAS OF CUM
COUNTY, PENNSYLVANIA _? Q 3' 23
ESTATE OF JENNIE D. CARSWELL,
Petitioner
V.
DISCOVER FINANCIAL SERVICES, LLC,
Respondent
It I L -
CIVIL ACTIO W, 09 COUNj'?
NNYI.`4aNi ??
No. /b -44.2-4/
PETITION FOR RULE TO SHOW CAUSE
AND NOW, this :;k 9t?' day of December, 2011, the Estate of Jennie D.
Carswell, by its attorneys, files the following Petition for Rule to Show Cause why Respondent's
Judgment should not be marked as "Satisfied In Full":
1. Petitioner is the Estate of Jennie D. Carswell, who died on January 17,
2011, while a resident of Cumberland County, Pennsylvania, whose last address was 32 S. Enola
Drive, Enola, PA 17025 (the "Estate").
2. Letters Testamentary for the Estate were granted to Debra K. Loew at No.
2011-00118 by the Register of Wills of Cumberland County, Pennsylvania on January 27, 2011
3. Respondent is Discover Financial Services, LLC also known as Discover
Bank, with offices located at 2323 Lake Club Drive, Suite 300, Columbus, OH 43232
("Discover")
3. On October 22, 2010, Respondent filed a Precipe for Default Judgment in
Cumberland County, Pennsylvania against Jennie D. Carswell at Civil Action No. 10-4624 Civil
.Y,
Term.
4. Jennie D. Carswell,deceased owned real property known as 32 S. Enola
Drive, Enola, Pennsylvania which is identified as tax parcel number 09-15-1291-056 (the "Real
Property").
5. The Estate notified Respondent of the death of Jennie D. Carswell.
6. Respondent filed a Claim against the Estate on April 4, 2011 in the office
of the Register of Wills of Cumberland County, Pennsylvania.
7. The Estate and Respondent reached a settlement regarding the amount
owed and the agreed upon sum was paid to Respondent.
8. On May 2, 2011, Respondent filed a Release of Claim with the Register of
Wills of Cumberland County, Pennsylvania.
9. The Estate sold the Real Property on September 15, 2011 and the sum of
$5,150.06 is being held in escrow because Respondent has not had its Judgment marked as
Satisfied.
10. The Estate has contacted Respondent on numerous occasions and has been
repeatedly advised that there is no money owed and that Discover would arrange for the
judgment to be marked satisfied.
11. The Estate has also contacted the legal counsel, Weltman, Weinburg &
Reis, Co., L.P.A. of 436 Seventh Avenue, Suite 1400, Pittsburgh, PA 15219, who filed the
judgment on behalf of Respondent.
2
. 1
12. The Estate was advised by Weltman, Weinburg & Reis that they no longer
had an active file in regard to this matter and that they could take no action unless Respondent
engaged them to perform additional legal services.
13. More than seven months have passed since the Claim against the Estate
was released by Respondent.
14. The Estate has received the requisite notice from the Commonwealth of
Pennsylvania that the inheritance tax has been paid in full.
15. All other required activity in the Estate has been completed and the Estate
is in a position to be distributed and closed.
16. The escrowed funds cannot be released to the Estate for purposes of final
distribution until the judgment filed in Cumberland County is marked satisfied.
WHEREFORE, the Estate respectfully requests that your Honorable Court issue a
Rule returnable within ten (10) days of its service on Respondent to show cause why the
judgment should not be marked as satisfied.
Respectfully submitted,
Vicky Trimmer, squire
Persun & Heim, P.C.
P.O. Box 659
Mechanicsburg, PA 17055-0659
(717) 620-2440
Attorneys for Estate of Jennie D. Carswell
4 .
VERIFICATION
I, Debra K. Loew, Executrix of the Estate of Jennie D. Carswell, have read the
foregoing Petition for Rule to Show Cause and verify that the facts set forth therein are true and
correct according to the best of my knowledge, information and belief and that as Executrix I am
authorized to execute this Verification on behalf of the Estate.
I understand that any false statement made herein is subject to the penalties of 18
Pa. C.S.A. §4904, relating to unsworn falsification to authorities.
Debra K. Loew
Dated: December 0?-Y , 2011
2s17sv1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND
COUNTY, PENNSYLVANIA
ESTATE OF JENNIE D. CARSWELL, CIVIL ACTION - LAW
Petitioner
V. No. 16-.y4.ay
DISCOVER FINANCIAL SERVICES, LLC,
Respondent
RULE TO SHOW CAUSE
AND NOW, this day of , upon consideration of the
foregoing Petition, it is hereby ordered that:
1. A Rule is issued upon Respondent to show cause why the Estate of Jennie
D. Carswell, Petitioner, is not entitled to the relief requested;
2. The Respondent shall file verified Answers to the Petition within
days of service upon the Respondent;
n
Petitioner of the Answers:
4- uP°riog afid/Qr arrtw ent if any, shall b.° 1' d
?..,?t ^'CIQCI( m in the. signa ('01irtr-aam e?`Ttim Gttrnbe'laff4 gA 4 y
5. If Items 3 and 4 above are left blank, depositions and/or argument or
hearing will be considered upon the request of any party; and
v
6.
Petitioner.
Notice of entry of this Order shall be provided to all parties by the
7. In the case of Preliminary Objections [Local Rule 1028(a)], Motions for
Judgment on the Pleadings [Local Rule 1034(a)] and Motions for Summary Judgment [Local
Rule 1035(a)], parties shall follow the procedures for disposition set forth in those rules.
By the Court'
00VR` ? ?Qne- a ? ?XY U? LPS u?
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WELTMAN, WEINBERG & REIS CO., L.P.A. hTA,I
BY: Sarah E. Ehasz, Esquire Attorney for Plaintiffs)
ll ''
I.D. No.86469 R WR -8
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
Phone: 412.434.7955
Fax: 412.434.7959
File # 8388988
DISCOVER BANK
Plaintiff
vs.
JENNIE D CARSWELL
Defendant(s)
iYPEN YLVAN A T
CUMBERLAND County
Court of Common Pleas
NO. 10-4624 CIVIL TERM
PRAECIPE FOR SATISFACTION OF JUDGMENT
TO THE PROTHONOTARY:
Please kindly Satisfy the Judgment of the above-captioned matter upon the records of the
Court and mark the cost paid.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By
Sworn to and subscribed
Before me they day qj/ , 2012
9, l' d
OTARY PUBLIC
?C
Sarah E. Ehasz, Esquire
Attorney for Plaintiff
COMM gNMI&Ib 21 NN?ItLVANIA
NOMM41 dal
Sheila G. Bev,1n, Notary Public
ROSS Twp„ Allegheny QpRLY
MY Commission ?c ros Noy 5, 2014
MEMBER, PENNSYLVANIA ASSOQA I ju NOTARIES
Q?f?9`SD?dI
?? ?# 103 937_ 3