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HomeMy WebLinkAbout10-4711SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~g,~~ta of +Lua~br~.r~~ (}f F ire <.: ' yE SH:RIFF ,.r Y~ r Jody S Smith Chief Deputy Richard W Stewart Solicitor Discover Bank vs. Elena Huiu Am ~ r • c~ I ljf r ' _ .. _ ~4~ r e- ~~~. Case Number 2010-4711 SHERIFF'S RETURN OF SERVICE 07/22/2010 08:20 PM -Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on July 22, 2010 at 1920 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Elena Huiu, by making known unto Tiberius Huiu, Son of defendant at 91/2 W. Main Street, Shiremanstown, Cumberland County, Pennsylvania 17011 its contents and at t am e handing to him personally the said true and correct copy of the same. ARK CO KLIN, DEPUTY SHERIFF COST: $41.50 July 23, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (cj CountySuite Sheriff. TeleosoR. Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK, Plaintiff(s) v. ELENA HUIU, Defendant(s) Docket No.: 10-4711 PRELIMINARY OB]ECTIONS TO COMPLAINT Filed on Behalf of Defendant Counsel: The J. Murphy Firm 210 Grant Street, #301 Pittsburgh, PA. 15219 (412)521-2000 Ashley M. Derr, Esq., Esquire Pa. Supreme Court I.D. 306604 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK, Plaintiff(s) Docket No.: 10-4711 v. ELENA HUIU, Defendant(s) CERTIFICATE OF SERVICE I, Ashley M. Derr, Esq., counsel for the Defendant in the above captioned matter, do solemnly swear that the foregoing P LIMINARY OBJECTIONS TO COMPLAINT BRIEF IN SUPPORT OF PRELIMINARY OBJECTIONS TO COMPLAINT MOTION/REQUEST/PRAECIPE FOR ARGUMENT were delivered by First Class, U.S. Mail, Postage Pre-Paid to the Below: James Warmbrodt, Esq. Weltman, Weinberg and Reis Co., LPA 436 Seventh Avenue, Suite 1400 Pittsburgh, Pa 15219 Respe fully Submitted, Ashl y M. De ,Esq. Wednesday, July 28, 2010 ' ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK, Plaintiff(s) V. f~ ~~ ELENA HUIU, `` Defendant(s) PRELIMINARY OBJECTIONS TO COMPLAINT '~~* Now comes the Defendant, by and through counsel, the ). Murphy Docket No.: 10-4711 Firm, and Ashley M. Derr, Esq., Esquire and bring(s) and file(s) the within N c~ i O ~~ ~ C -~ T~ .J-~~ ~ i~:~. .T ~~ r, , .., W ;~ -:; Preliminary Objections to Complaint, averring in support thereof as follows: OBJECTIONS TO CONTRACT CLAIMS 1. The Complaint references a credit agreement or contract. 2. No averment is made as to whether said agreement is oral, or written. 3. The foregoing amounts to a violation of Pa. R.C.P. §1019(h), as amended, which requires that, "When any claim or defense is based upon an agreement, the pleading shall state specifically if the agreement is oral or written." 4. Accordingly, the Complaint is the proper subject of preliminary objections pursuant to Pa. R.C.P. 1028(a)(2) for violation of rule of court 1019(h). 5. Although the Complaint references a credit agreement or contract, no copy of the agreement or contract is attached thereto. 6.~ The foregoing amounts to a violation of PA. R.C.P. §1019(1). 7. Accordingly, the Complaint is the proper subject of preliminary objections pursuant to Pa. R.C.P. §1028(a)(2) for failure to conform to Rule of Court 1019(1). OBJECTIONS DIRECTED TOWARD LACK OF SPECIFICITY 8. Pa. R.C.P. 1019(f) requires, interaiia, that items of special damage be pled with specificity. 9. In the context of a credit card case, items of special damage, which are to be specifically pled, include the dates and amounts of charges, fees, fines, interest, and the like. 10. In the context of a credit card case, the requirements of 1019(f) are normally met by attaching copies of an un-interrupted chain of credit card statements, starting with a zero balance and ending with a statement showing the amount sought in the complaint. 11. It is respectfully submitted that the neither the Complaint, nor the documents attached thereto, specifically plead the items of special damage underlying the case. 12. This renders the Complaint the proper subject of preliminary objections, pursuant to Pa. R.C.P. 1028(a)(2), for failure to conform to Rule of Court 1019(f), and the proper subject of preliminary objections, pursuant to Pa.R.C.P. 1028(a)(3) for insufficient specificity. WHEREFORE, Defendant respectfully prays that the Complaint filed by the Plaintiff be dismissed with prejudice, or, in the alternative that the complaint be stricken, and the Plaintiff be required to plead over in accord with the Rules of Court. Respectfully Submitted, A hley M. Derr, Esq. 4IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK, Plaintiff(s) Docket No:: 10-4711 v. ELENA HUIU, Defendant(s) -ORDER- On this day of , 20 , it is hereby ORDERED that Plaintiff's Complaint is stricken. Plaintiff may file an amended complaint within 30 days. If Plaintiff fails to file an amended complaint within the time set forth above, the Prothontary, upon praecipe of the Defendant, shall dismiss this case with prejudice. BY THE COURT: J. t/A~AL ~~ PRAECIPE FOR LISTING CASE FOR ARGUMENT (Must be typewritten and submitted in triplicate) TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Argument Court.) CAPTION OF CASE (entire capfion musf be stafed in full) D~sco~v~~~ VS. ~q ~U (List the within matter for the-l~zt ~~ No. / d _ ~ 1 ~ f Term 1. State matter to be argued (i.e., plaintiffs motion for new trial, defendants demurrer to complaint, etc.):~,.F„~,,,,IN ~A ~;, "T7.~,1 ~inn,inn ~~ ~ /i'/., ,~ e~nnir 2. Identify all counsel who will argue cases: (a) for plaintiffs: ~~ J, MUFPFY FIRM 01 P6H.. PA 15219 3. 1 will notify all parties in writing within two days that this case has been fisted for argument. 4. Argument Court Date: INSTRUCTIONS: 1. Two copies of all briefs must be filed with the COURT ADMINISTRATOR (not the Prothonotary} before argument. 2. The moving party shall file and serve their brief 12 days prior to argument. 3. The responding party shall file their brief 5 days prior to argument. 4. If argument is continued new briefs must be filed wRh the COURT ADMINISTRATOR (not the Prothonotary) after the case is rellsted. 1~ and na ~, ; . f --` - r'~`' ~J _. ~` ~ ~~ t_ 1 Attor for 7 Lf~ y Date: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DISCOVER BANK, Plaintiff V. ELENA HUIU, Defendant. CIVIL, DIVISION Docket No.: 10-4711 ANSWER TO AMENDED COMPLAINT AND NEW MATTER Filed on behalf of Defendant ELENA HUIU Counsel of Record for this Party: Lt C ZZ fJ r=iF-- C:) - .J >- Ashley M. Derr, Esquire wa: z --JV) Pa. I.D. #306604 iL W Mw y O. The J. Murphy Firm 210 Grant Street, Suite #301 Pittsburgh, Pa 15219 (412) 521-2000 ®RIVIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL, DIVISION DISCOVER BANK, Plaintiff V. ELENA HUIU, Defendant. Docket No.: 10-4711 Certificate of Service I do solemnly swear that a true and correct copy of the within ANSWER TO AMENDED COMPLAINT AND NEW MATTER was delivered to the below party or counsel as follows: Sarah E. Ehasz, Esquire WELTMAN, WEINBERG & REIS CO., L.P.A 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 [ XX ] Via First Class U.S. Mail, Postage Pre-Paid [ ] Via Facsimile: [ ] Via Certified U.S. Mail, Postage [ ] Via Express Mail Pre-Paid Carrier: Article Number [ ] Via Certified U.S. Mail, Postage [ ] Other Method as follows: Pre-Paid, Return Receipt Requested. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL, DIVISION DISCOVER BANK, Plaintiff Docket No.: 10-4711 V. ELENA HUIU, Defendant. ANSWER TO AMENDED COMPLAINT AND NOW, comes the Defendant, comes Defendant, ELENA HUIU, by and through his attorneys, THE J. MURPHY FIRM and ASHLEY M. DERR, ESQUIRE, and files the within Answer to Amended Complaint and avers as follows: ANSWER 1. Paragraph 1 of Plaintiff s Complaint is admitted. 2. Paragraph 2 of Plaintiff s Complaint is admitted. 3. Paragraph 3 contains a conclusion of law for which no reply is necessary. By way of further answer, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments. Therefore, the averments are specifically denied and strict proof is demanded at the time of trial. COUNT 1- BREACH OF CONTRACT 4. Paragraph 4 of Plaintiff s Complaint requires no response. 5. The allegations contained in Paragraph 5 are admitted in part and denied in part. While it is admitted that the Plaintiff mailed Defendant a credit card, Defendant is without knowledge or information sufficient to form a belief that Plaintiffs Exhibit "1" is in fact the agreement. Therefore, this averment is specifically denied and strict proof is demanded at the time of trial. 6. Paragraph 6 contains a conclusion of law for which no reply is necessary. By way of further answer, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments. Therefore, those averments are specifically denied and strict proof is demanded at the time of trial. 7. Paragraph 7 of Plaintiffs Complaint is overly broad. By way of further answer, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments. Therefore, the averments are specifically denied and strict proof is demanded at the time of trial. 8. Paragraph 8 contains a conclusion of law for which no reply is necessary. By way of further answer, while it is admitted that the Plaintiff has attached a series of statements setting forth payments, charges, and interest charges to their Amended Complaint as Exhibit "2", Defendant is without knowledge or information sufficient to form a belief that the interest rate, charges and other fees contained on said monthly statements are accurate. Therefore, those averments are specifically denied and strict proof is demanded at the time of trial. 9. Paragraph 9 contains a conclusion of law for which no reply is necessary. By way of further answer, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments and strict proof is demanded at the time of trial. 10. Upon reasonable investigation, Defendant is without: knowledge or information sufficient to form a belief as to the truth of the averments contained in Paragraph 10. Therefore, the averments are specifically denied and strict proof is demanded at the time of trial. 11. Upon reasonable investigation, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments contained in Paragraph 11. Therefore, the averments are specifically denied and strict proof is demanded at the time of trial. 12. Paragraph 12 contains a conclusion of law for which no reply is necessary. By way of further answer, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments. Therefore, those averments are specifically denied and strict proof is demanded at the time of trial. 13. Paragraph 13 contains a conclusion of law for which no reply is necessary. By way of further answer, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments. Therefore, those averments are specifically denied and strict proof is demanded at the time of trial. 14. Paragraph 14 contains a conclusion of law for which no reply is necessary. By way of further answer, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments. Therefore, those averments are specifically denied and strict proof is demanded at the time of trial. 15. Paragraph 15 contains a conclusion of law for which no reply is necessary. By way of further answer, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments. Therefore, those averments are specifically denied and strict proof is demanded at the time of trial. 16. Paragraph 16 contains a conclusion of law for which no reply is necessary By way of further answer, Defendant did not willfully fail, nor did he refuse to pay the principal balance or any other charges. Therefore, those averments are specifically denied and strict proof is demanded at the time of trial. 17. Paragraph 17 contains a conclusion of law for which no reply is necessary. By way of further answer, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments. Therefore, those averments are specifically denied and strict proof is demanded at the time of trial. 18. Paragraph 18 contains a conclusion of law for which no reply is necessary. By way of further answer, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments. Therefore, those averments are specifically denied and strict proof is demanded at the time of trial. COUNT II-UNJUST ENRICHMENT 19. Paragraph 19 of Plaintiff's Complaint requires no response. 20. Paragraph 20 of Plaintiff's Complaint is overly broad.. By way of further answer, Defendant is without knowledge or information sufficient to form a belief as to the truth of the averments. Therefore, those averments are specifically denied and strict proof is demanded at the time of trial. 21. Paragraph 21 is specifically denied. The benefit of goods and merchandise was not conferred upon the Defendant by the card or the Plaintiff: Rather, the goods and merchandise were provided by the merchants who sold the goods and merchandise to the Defendant. The only "benefit" conferred upon the Defendant by the card or Plaintiff was an extension of credit. Therefore, those averments are specifically denied and strict proof is demanded at the time of trial. 22. Paragraph 22 contains a conclusion of law for which no reply is necessary. By way of further answer, Defendant did not willfully fail, nor did he refuse to pay the principal balance or any other charges. Therefore, those averments are specifically denied and strict proof is demanded at the time of trial. NEW MATTER 23. The Defendant also Pleads to the extent Plaintiff suffered any damages, which Defendant expressly denies, Plaintiff has failed to take the steps necessary to mitigate the damages sustained. Respectfully Submitted: THE J. err, Esquire Defendant) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DISCOVER BANK, CIVIL DIVISION Plaintiff, NO: 2010-4711 V. ELENA HUIU, PLAINTIFF'S REPLY TO DEFENDANT'S . . NEW MATTER r3 .? ; , Defendant -- _t . ?? "' r r ? °a T F 1 ;0c) -<X" C) _: '.?'? 'Z7 tJ'y e FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD FOR THIS PARTY: Sarah E. Ehasz, Esquire Pa. I.D. # 86469 WELTMAN, WEINBERG, & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: (412) 434 -- 7955 Fax: (412) 338 - 7130 WWR# 8400235 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DISCOVER BANK, CIVIL DIVISION Plaintiff, NO: 2010-4711 V. ELENA HUIU, Defendant. PLAINTIFF'S REPLY TO DEFENDANT'S NEW MATTER AND NOW, comes the Plaintiff, DISCOVER BANK, by and through its counsel, Weltman, Weinberg, & Reis Co., L.P.A., and files the following Reply to Defendant's New Matter, averring as follows: NEW MATTER 23. Paragraph 23 of Defendant's New Matter is a conclusion of law to which no response is required. To the extent that a response may be deemed necessary, same is denied and strict proof thereof is demanded at trial. By way of further response, any and all insinuations or allegations of wrongdoing on the part of the Plaintiff are strictly denied. WHEREFORE, Plaintiff respectfully requests that this Honorable Court find in favor of the Plaintiff and against the Defendant. Respectfully Submitted, Sarah E. Ehasz, Esquire Pa. I.D. # 86469 WELTMAN, WEINBERG, & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: (412) 434 - 7955 Fax: (412) 338 - 7130 WWR# 8400235 CERTIFICATE OF SERVICE The undersigned hereby certifies that a true and correct copy of the within Reply to Defendant's New Matter has been sent to the following parties by first class, U.S. Mail, postage prepaid, this ! day of 011, as follows: Ashley Derr, Esquire The J. Murphy Firm 210 Grant Street, Suite 301 Pittsburgh, PA 15219 Sarah E. Ehasz, Esquire Pa. I.D. # 86469 WELTMAN, WEINBERG, & RAMS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: (412) 434 - 7955 Fax: (412) 338 - 7130 WWR# 8400235 r It 9kg0023s' IN THE COURT OF COMMON PLEAS OF S LJ v e.? ??„? ?c CUMBERLAND COUNTY, PENNSYLVANIA (VS) NO. #td u L ? rn r ? "IF ?nti -- G? 3- o O"rt Wit-, RULE 1312-1 The Petition for Appointment of Arbitrators shall be substantially in tR = N 3? Following form: . cc. PETITION OR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: A , a,,9A" r'1 'v .- counsel for the plainti ceded' in the above action (ergs), respectfu y represents that: 1 The above-captioned ac 'on (epeetiem) is (M } at issue. / 2. The claim of plaintiff in the action is S qq / , yq The counterclaim of the defendant in the action is The following attorneys are A44 asarbitrators: &V ,). UriJ. A . WHEREFORE, your petitioner whom the case shall be submitt AND NOW, petition,_ Esq., and captioned action (or actions) as in the case(s) as counsel or are otherwise disqualified to sit P rr , el6 `I . J )e PL-1 J tin -?' your Honorable Court to appoint three (3) arbitrators to Rc,, Dectfully submitted, ORDER OF COURT av' %.Dg60 N P tiabgogs S b 9*a sto 00 200 , m consideration of the foregoing Esq., and Esq., are appointed arbitrators n the above for. By the Court, EDGAR B. BAYLEY r CERTIFICATE OF SERVICE A true and correct copy of the within Petition for Appointment of Arbitrators, for an Arbitration Hearing, has b n served by U.S. Mail, Postage Pre-Paid, on of 1 kr C 20 C 1 upon the following: ASHLEY DERR, ESQUIRE THE J. MURPHY FIRM 210 GRANT STREET, SUITE 301 PITTSBURGH, PA. 15219, By: r 1 ???yoD23s" ? l_ & 1N THE COURT OF COMMON PLEAS OF PENNSYLVANIA CUMBERLAND COUNTY 'F , NO. u-'64 G m .? r, n6, j ?r n . 4 . ;oc v o < xr Zo o-n mac, RULE 1312-1 The Petition for Appointment of Arbitrators shall be substantially in tW tv Following form: -G -? PETITION FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: /%44e,a ?)- ur??a 6 u -,-e , counsel for the pin the above action {ergs}, respectfu,[1y represents that. I TV, abov?-captioned action (epeetieom) is (m} at issue. 2. The claim of plaintiff in the action is S qq The counterclaim of the defendant in the action is The following attorneys are interested in the case(s) as counsel or are otherwise disqualified to sit as arbitrators: .=F+F / Ad le? Per• t" ?-V _ WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Re.: aectfully submitted, ankh sa4.oo Pd ?j ORDER OF COURT P*asb ybo AND O;fJ, 201(/r , in consideration of the foregoing petition, ?`-- Esq., and) Esq., an Esq., are appointed arbitrators :.Ti the above 'If captioned acticn (or actions) as praye for. A" 'J :; d ' r' 's N 1 ?jvt I f-tt1nl.1 I '?11 _1 ',111 ixl Vna4Aea) b Ur! an (?pp;?s r??a.l?rt' 31ar Ill By the Court, r ` r CERTIFICATE OF SERVICE A true and correct copy of the within Petition for Appointment of Arbitrators, for an Arbitration Hearing, has been served by U.S. Mail, Postage Pre-Paid, on 7 of M-kr C h , 20 11 upon the following: ASHLEY DERR, ESQUIRE THE J. MURPHY FIRM 210 GRANT STREET, SUITE 301 PITTSBURGH, PA. 15219 By: DISCOVER BANK, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY, PENNSYLVANIA : vs. CIVIL ACTION - LAW NO. 10-4711 CIVIL ELENA HUIU, Defendant ORDER AND NOW, this /S-` day of April, 2011, the appointment of Melissa Tanquay, Esquire, as a member of the Board of Arbitrators in the above-captioned case is VACATED. Craig Kauzlarich, Esquire, is appointed in her place. BY THE COURT, Ron Turo, Esquire Chairman, Board of Arbitrators Court Administrator Am Copes ma.Ied YIIf/II OV- V'rrn -0 r*t -<? co ej, JAI S GO(/ 3 Q In The Court of Common Pleas of Cumberland Plaintiff / / County, Pennsylvania No.<o - Defendant Civil Action - Law. Oath We dos emnly swear (or affirm) that we will support, obey and defend the Constitution of the United States A the Constitution of this Commonwealth and that we will discharge the duties of our office with delity. fIgnature Signature Signature Name (Chairman) Name Name PC . /fib©h ? rv r ? 47 Law Firm Law Firm Law Firm A) ? ? S? 3" /,,, - -/ -?,) 4 - ?d* Address Address Address 703 City, Zip City, Zip city, 'zip Notice of Entry of Award Now, the J 7 day of zZail '20 // , at // = // , /1 .M., the above award was entered upon the docket and notice t ereof given by mail to the parties or their attorneys. Arbitrators' compensation to be paid upon appeal: $ 3Se • 270 By: Prothonotary Deputy Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated.) OF HE PRCTHONOTAR`_' 2011 APR 27 AM 11: 1 1 CUMBERLAND COUNT' PENNSYLVANIA As 4 /e /Serr Erb lo,p ; els ma, %eof' Arz FILED-OFFICE 01- SHE PROTHONOTARY 2011 JUN 15 PM 3: 28 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. ELENA HUIU Defendant No. 10-4711 CIVIL PRAECIPE FOR JUDGMENT ON AWARD OF ARBITRATORS FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T Molczan, Esquire PA I. D.#47437 Wellman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#08400235 Dur?n+ $ l ?f. {? d CL ?k ? 9??9y8,a r???foo s5 M A ; L J IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. ELENA HUIU Defendant Civil Action No. 104711 CIVIL PRAECIPE FOR JUDGMENT ON AWARD OF ARBITRATORS TO THE PROTHONOTARY: Enter Judgment against Defendant, ELENA HUIU, on the Award of Arbitrators in the amount of $8000.00. 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: y--- William T Molczan, Esquire PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#08400235 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendantl is: 9 1/2 W MAIN ST, CAMP HILL, PA 17011 Plaintiff a,?? Defendant In The Count of Common Pleas of Cumberland County, Pennsylvania No./O. „?7/ Civil Action - Law. Oath !1ates e do s lemnly swear (or affirm) that we will support, obey and defend the Constitution of the United d the Constitution f this Commonwealth and that we will discharge the duties of our office ith delity. gnature 5ianature ? Signature Name (Chairman) Law Finn Address City, Zip Dom; ??. t'I?ar??neuI/t Name .?ti, f?Wl?rly? ????.r.5 ?C• Lase Firm ' 6p r Name -40,p, 4- ,,rtj *?5 Law Firm Address r Address /70 City,. Zip city, i P Award We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they shall be separately stated) i 11 - ?' :. -/1 itrator, dissents. (Insert name if applicable Date of Hearing: Date of Award Chairman Notice of Entry of Award Now, the 7 day of , 20__y , at /P/ / !Z entered upon the docket and notice t ereof givenby mail he parties or their atto eeYs.Bove award was Arbitrators' compensation to be paid upon appeal: $ 3SG7. 46) -'D By: Prothonotary Deputy r WELTMAN, WEINBERG & REIS CO., L.P.A. TA BY: Sarah E. Ehasz, Esquire Attorney for Plaintiff(s) ? k , , I.D. No.86469 436 Seventh Avenue, Suite 1400 f OERLAM) COUNTY Pittsburgh, PA 15219'?'?`?(tAIg f 17 Phone: 412.434.7955 Fax: 412.434.7959 File # 8400235 DISCOVER BANK Plaintiff CUMBERLAND County Court of Common Pleas vs. ELENA HUIU Defendant(s) NO. 10-4711 CIVIL 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 IS CO., . A. By Sarah E. Ehasz, Esq ' e Attorney for Plainti ??lD4F78? 5 ti -7 Yce,3 (e