HomeMy WebLinkAbout10-5685
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3jD..2 ANI9'i5
CUM PRL4 1?) COUNTY
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff No: 10 - 5085 C,ivil?Et 1?!
vs.
COMPLAINT IN CIVIL ACTION
BROOKE A BECK
Defendant FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
James C. Warmbrodt,42524
WELTMAN, WEINBERG & REIS, CO., L.P.A.
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434-7955
FAX: 412-338-7130
08543832 C A Pit CXC
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No
BROOKE A BECK
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 loe
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:
BROOKE A BECK
403 GLENN AVE'
BOILING SPRGS, PA 17007
3. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXX7331 .
4. Defendant made use of said credit card and has a current balance
due of $4064.26 , as of July 08, 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
22.240% per annum on the unpaid balance from July 08, 2010 . A copy of
Plaintiffs Statement is attached hereto, marked as Exhibit ''1l, 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 , BROOKE A BECK individually , in the amount of
$4064.26 with interest at the rate of 22.240% per annum from July 08,
2010 plus attorneys' fees of $125.00 , and costs.
WELT , WEINBERG & REIS CO., L.P.A.
436 S v nth Avenue, Suite 1400
Pitt u gh, PA 15219
(412 4-7955
FAX 4 2-338-7130
085 3 32 C A Pit CXC
This law firm is a debt collector atte ing to collect this debt for
our client and any-information obtain will be used for that purpose.
DISCOVER Now Balance Minimum 7Pymennt Due Account Number ending in 7331
51,008.0Enter Amount Enclosed Below
Payment Due Dais $ -?
July 25, 2010
30 SDSNOA01 OOpf 180
BROOKE BECK
403 GLENN AVE
BOILING SPRGS PA
17007-9528
Address, e-mail or telephone change$
Go to www.Discover eem or print change in space above.
mof?tion more secure your account
passuvord-
protected statements only you can access.
m more at discover corrdpaperless.
PO BOX 6103 of 11 gill
CAROL STREAM IL 60197-6103
Itl[,tl6rrtttllltlrtLr,Itllttrttlllhnttd611rrrtnlLJrtll
OOOUD1986458171510726000000000000001J10D8a0
Aming Dais: June 11, 2010 - posing Daft: June 3(
Discover More Card Account Summary number ending in 7331
Previous Balance $4,064.26
Payments And Credits - 4,064.26
Purchases + 0.00
Balance Transfers + 0.00
Cash Advances + 0.00
Interest Charged + 0.00
Fses Charged + 0.00
New Balance r0 06
See Interest Charge Calculation section following
transactions for detailed APR information
Credit Line $3,800.00
Credit Line Available $0.00
Cash Advance Credit Line $2,000.00
Cash Advance Credit Line Available $0.00
Cash k Bonuse Anniversary Month
March
Opening Cashbock Bonus Balance $ 0.00
New Cashbock Bonus This Period + 0,00
Cashbadc B.- Balano $ 0.00
To barn more, 4 in at www.Dinover.com and select Rewards
I, 2010
Payment Information
New Balance $0.00
Minimum Payment Due $1,008.00
Payment Due Date July 25, 2010
Lola Paymw* Warning: If we do not receive your.minimum
payment by the date listed above, you may have to pay a late
Fee of up to $39.00 and your purchase APRs for new
transactions may be increased up to the Penally APR of
27.24% variable.
Manage Your Account Online at www.Discovw.corn
• Securely access statements and free online tools, pay bills
online and track and view aA transactions simply and easily
• Make your money worth more sm-find easy ways to *am
and redeem cash rewards
• NEWT Access your account securely through your
mobile phone
3 Easy Ways to Contact Us
1. Access your account securely at www.Discaver.corn
2. Coll 1-800.DISCOVER (1-800347-2683)
Please have your Discovers card available
3. Write b us at Discover, PO Box 30943,
Sall Lake City, LIT 84130
For TDD (Telecommunications Device for the Deal)
assistance, please call 1-800347-7449.
Transactions
Trans. Post
Dale Dols
Payrnents and Credits Jun 30 Jun 30 INTERNAL CHARGE-OFF t d OAA 9A
f105 TOTAL FEES FOR THIS PERIOD $ 0.00
Inlerest Charged TOTAL INTEREST FOR THIS PERIOD $ 0.00
: AU 1 U 1 otals Year-to-Date
TOTAi FEES CHARGED IN 2010
TOTAL INTEREST CHARGED IN 2010
23400
411 96
1862Charge Calculation
Your Annual Percentage Rate (APR) is the annual interest rate on your account.
Current B&S Period: 20 days RRAATEE ?R) ERCENTAGE NCE
IN BALA EST RATE ECi TO INTEREST CHARGE
Purchases 22.24% V s0 $0
Cash Advances 29.99% V $0 $0
V - Variable Rate
Additional Lmportant
Mormation
Important Information. 0 there is more than one page to this billing statement, see the back of each page for o"Plonal important information
Continued on reverse side.
DISCOVER
See your Cardmember Agreement. Your Cordmember Agreement contains all the terms of your Account
Last or stolen cads. Report imnedatefy! Call 1-800-347-2683.
What To Do 9 You Thank You Find A A4 slam On Your Soco meet
If you think dare is an error on your statement, who a us at Discover, PO Box 30421, Soh take City
UT 84130-0421
,
In your laser, give us the Following Information
• Account iriFwmayon; Your name and account number
• Dollar amount. The dollar amount of the suspected error
• Description d Problem' t you Thick there is an error on your 6611, describe what you believe is wrong and why you believe Ris a mistake
You must contact us within 60 days after the error appeared on your statement
You must notify us of any potential errors m writing. You may call us, but if you do we we not required to investigate my potential errors and you may have to
pay the amount in qussian
While we investigate whether or not there has been an error, do following are hue
• We cannot try to called the amount in question, or report you as delinquent on that amount
The charge in 0.an may remain an your statement, and we may continue to charge you interest on that amount Out if we determine that we made a
mistake, you wet not have (a pay the amount In question or any Interest or other fees related to that amourd
While you do not have to pay de amount in question, you am responsible For the remainder of your balance
We can apply any unpaid amourY against your credit limit
Your Rigfits If You Are Dissatisfied With Your Credit Card Purchases
R you are dissatisfied with the goods air services that you have purchased with your credit card, and you have tried in good faith to correct to
problem with the merchant, you may have the right not to pay the remaining amount due on the purchase
To use this right, all of the Following must be true
1 The purchase must have been made in your home sine or within 100 miles of your current mating address, and the purchase price must have
beers more tan S50 (Nate: Neither of these are necessary t your purchase was based man ad
ti
ver
sement we mailed to you, or if we own
the company that sold you the goods or services. )
2 You must have used your credit card For the purchow Purchases made with cash odmmes from an ATM or with a check that accesses your
credit card account do not quality
3 You must not yet have fully paid far I he purchase
t all of the criteria above are awl and you are still dissatisfied with the purchase, contact us in wrdmg at Discover, PO Box 30945,
Soh Lake City
UT 841300945
0
,
While we inves'
hgab, tse same rules apply to the disputed amount as discussed above After "finish our mvestigation, we will tell you our
decision At tat point, if we think you owe m omount and you do not pay we may report you as delinquent O
Z
W
Payments. Send only your payment and to zap portion of this statement into envelope provided Do nat send cosh By sending your check as described
above, you authorize us to use information on your check to make on electronic fund transfer from your account at the fina
i
l i
tit
i
i
d o
nc
a
ns
ut
on
n
icated on yaw
check or to process the payment as a check transaction R payment is processed as an electrmic fund transfer, to transfer will be for" amount of to check
When we use information from your check to make an electronic fund transfer, Funds itiay be withdrawn From
our o
t
t
$
y
ccoun
as som as
he some day we receive
your payment, and you will not receive your check back from your financial Institution U
The processing of your payment may be delayed IF you send cash, correspondence or other items with your payment, ifilityyou send the payment to any other
you use an en
be cre address or 0f
than the me provided Payments received in proper form at our processing fac by SPM local time m an
da
ill
lops t
N
y
y w
o
tit
ot
b. of you un dry ?yments received at ow processing facility after 5PM local ime wig bs credited to your Account as of the nexo
pla i ? envelope
ment to Discov
y Y° have ai
Y? pa
r
PO B
6103
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,
y
,
e
ox
,
ar
Sheam, It 60 1 97-6 103 Please allow 7-10 days For delivery
of
s
your payment is unpaid, we reserve the right to resubmit it as on electronic debit
You can pay your minimum payment or a greater amount over the telephone, and you can set up outomafic payments Coll us at I-SM347-2683 You will
need dus statement and your bank account ktermahon You must ensure that sufficient funds are available in your bank account, and all transactions must
comply wish U S low You will be asked t
id
th
fi
d
o prov
e
e
rst 5
igits of your account statement LP code By entering Lasenumbers m your electronic
sign you will be agreeing s this authorization to allow us and your bank to deduct each paymnatt you audarta om your bank account, and to fnitiote
debit w credit entries to your bank account
as applicable
to correct an error i
t
r
i
f
,
,
n
o p
ocess
ng o
such payment You must fell us to amount of each payment
or you can select an amount such as the Minimum Payment Due or to Now Balance on each statement You can cancel a payment however we must receive
notice at least three business days in advance at. the scheduled payment You ma
notif
u
b
h
1
800
y
y
s
y p
one at
-
-347-2683 or by mail at tw address listed in the
Y s"iom parogmph t Your payments vary in amount, we will tell you an each monthly statement when yaw payment wig be mode and taw much it will be
1 our automatic payment amount ma
b
l
oh
i
di
d
y
e
ess
m
n
cate
on the monthly statement based on credits or payments applied during the billing cycle
Credit Reporting. We may report onformaton about your Account to credit bureaus bb payments, missed payments, or other defoults an your Account
may be reflected in your credit report We normally report to status and payment histor
of
aw A
t t
di
y
y
ccoun
o cre
t reporting agencies each month if you
believe that our report is inaccurate m incomplete, plegim write us at the following address. Discover
PO Box 15316
Wil
t
DE 1
,
,
ming
on,
98505316 Please
indicate your name, address, home telephone number and Account number
Paying Intend: We begin to Impose Inowesl Charges on dl fans ixtons from the Transaction Date for the transaction shown an your bilk statement
unless a hansacfion is posted to your Account after to close of the lu'Airg period in which it occurs, in which case we begin to impose interest charges on tat
transaction From the first day of" biting period in which it Is posted to your Account We contin
t
I
I
h
ue
o
mpose
nterest C
arges until the dae you pay your
entire New Balance shown an yaw billing sakment by mid payments or receiving credits R you paid the New Balance on your previous billing statement
by the Poyymmeeno Due Dale shown an that ballin
t
t
ill
g s
a
ement we w
not impose Interest Charges m new purchases, that is, purchases first ring on the
ll 06
current boiling statement, or any portion of a new purchow paid by to Payment Due Dale on yaw current billin
stateme
t W
'
g
n
e ca
grace period
It
is not Less than 25 days There is no grace period an balance transfers or cash advances As more fully described in to section of yaw Cordmember
Agreement holed 'How We Apply Payments,' we generally apply po Is to your Account baud on the APR applicable to The 6olmce of each transaction
category This means that if you do not
a
the New Bal
1
b
p
y
ance on
current
illing statement by the Payment Due Date shown an that billing statement, ten,
depending an the amount of your payment and the APRs on other b
l
a
ances, you may not get a grace period m new purchases
Minimum Interest Charge. We will charge you a minimum Interest Charge of S 50 far any boiling period in which Interest Charges of less than $ 50
would otherwise be imposed
Annual Fee. R your Account has an annual Fee, a will be billed at to beginning of each amiverory year your Account is open The amount of the ire
appears on the statement when the fee is billed The annual fee is not refundable unless
ou
tif
t
h
y
no
y us
sar you wis
to close your Account within 30 days of the
moiling or delivery date of the statement on which tea Fee is billed You will receive this refund even l you use your Card dwing that period
How We Calculate Interest Charges - Daily Balance Method (including current transactions): We figure Interest Charges For each billing
period To do this
We calculate your Interest Charges separately for each balance object to different terms (kw example, standard purchases, standard cash
advances and each purchow, bolonce transfer and cash advance balance subject to promotional terms) We mfer to these balances as
transaction catagoriea
• We Figure the 'daily balance' for each transaction category To ggof to "daily balance" we take the beginning balance Fur each day, add any
new transactions and fees and my Interea Char
es accr
d
If
i
d
'
g
ue
an
e prev
ous
ay
s daily balance We then subtract any credits and nh and
make other adjustinents (including Laseodi-tinents required in the section filled 'P i Interest') b cakulotir
the doil
bal
f
u
y
h
B
d
g
y
ance
o
r
l
rso
e
ay of the billing period, we consider to *previous days daily balance' to have been your balance on the lost day of yaw previous billin
eriod Thi
i
t
d
l
b
g
p
s g
ves us
he
ai
y
alance for each transaction category
We figure to Interest Charges an your Account by multiplying the duty boance for each transaction category by its daily periodic rate, for each
day in the billing period
The total Interest Charges for the boiling period are the sum of the dally Interest Charges for each transaction category for each day during that
billing period
When we calculate daily baances, we add a new, transaction as of the Transaction Date shown on your billing statement unless the transaction is posted a
yyoouur Account after the close of the billing period in which it accurs, in which cane the transaction will be odded to the daily balance as of the first day of the
blhng period in which it is
o
t
d t
A
p
s
e
o your
ccount AR fees charged to your Account are added to dw standard purchase transaction category with the
exception of Cash Advance Fees which are added a the applicable cash advance transaction category and Balance Transfer Fees which are added a the
applicable balance transfer transaction category
lo_"8982ncy Fee: 2% of the U S. dollar amount of each purchase made in a forei
n curre
g
ncy
Penalty APRs: Each time you foil to make a payment when due, we may, in accordance with applicable law, Ii) terminate the availability ol any
introductory/promohorhal APRs on new tranoctms, and (hi) increase your APRs For new transactions to variable Penalty APRs which will be det
rm
d b
dd
ddi
t
i
l
up
e
ine
y a
o an a
ing
ona
t
5 percentage points to the otherwise applicable APR Your Penalty APR is determined based on your creditworthiness and other Factors such
as your current APRs, and your account history t your APRs for new transactions are increased for a late payment to Penalty APRs will apply Indefinitely
For TOO (Telecommunications Device for the Deal) assistance, please call 14100-347-7449.
Discover may monitor and/or record telephone calls between you and Discover representatives for qualify assurance purposes.
The Discoverm card is issued by Discover Bank, Member FDIC
O MK 172
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# 8543832
Brooke A. Beck
6011002030747331
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson flLED-D79CE
J r
Sheriff T!-;r ^n!
Jody S Smith
Chief Deputy 10 SEEP -'9 Ali 8: 45
rt
t
Richard W Stewart
SOiIC(tOr CUM-6C' J-u,t?d?4--)?/At..?itiJAtJIYf 1
(?E V! Vti 1 V VJA
Discover Bank
vs.
Brooke A. Beck
Case Number
2010-5685
SHERIFF'S RETURN OF SERVICE
09/03/2010 05:59 PM - Gerald Worthington, Deputy Sheriff, who being duly sworn according to law, states that on
September 3, 2010 at 1759 hours, he served a true copy of the within Complaint and Notice, upon the
within named defendant, to wit: Brooke A. Beck, by making known unto herself personally, at 403 Glenn
Avenue, Boiling Springs, Cumberland County, Pennsylvania 17007 its contents and at the same time
handing to her personally the said true and correct copy of the same.
SHERIFF COST: $33.40
September 07, 2010
GERALD W RTHIN N, DEPUTY
SO ANSWERS,
RON R ANDERSON, SHERIFF
f,i Coun':.ySu?to Stw-,it Teleosott_ ii^
S
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DISCOVER BANK
vs
BROOKE A BECK
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Plaintiff No: 10-5685 CIVIL, Ti?RM
PRAECIPE FOR 'DEFAULT JUDCP~IEN_~'
Defendant FILED ON BE~iAL~F OF
Plaintiff
COUNSEL OF' RECORD OE'
THIS PARTY:
James C. Warm~x~rcdt,42524
WELTMAN, WF' .NBER_G & RE S C:C . L . ;? . r,.
436 Seventh Avenue, Suite 1400
Pittsburgh, Ph 15219
(412; 434-7955
FAX: 41.2--338-"/13C
08543832 C A Pit ALL
Judgment Amc~ar_t $4:443.3'%
DISCOVER BANK
Plaintiff
vs.
BROOKE A BECK
TO THE PROTHONTARY:
IN THE COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Civil Actior_ No. 10-5685 CIVIL TEKM
PRAECIPE FOR DEFAULT JUDGMENT
Kindly enter Judgment against the Defendant BROOKE A BECK above named,
in the default of an Answer, in the amount of $449 ~~ . 87 corlp~_zted as f chows
Amount claimed in Complaint $~E064.?6
Less payments / adjustments made $C.00
Interest on the remaining principal. balance of
$4064.26 from July 08, 2010 to October. 19, 2010
Ca the interest rate of 22.24Co per annum $254.61
Attorney's fees $125.00
TOTAL $4443.87
I hereby certify that appropriate Notices of Defau]_t, as attached have
been mailed in accordance with PA R.C.P. ?_37.1. on t=he dates ir.dicar_ed on ?.he
Notices.
WEL7'MAN, wEINBERG & KEIS CO. I:.,.P.A.
By
James C. W
08543832
Plaintiff's address is:
c/o WELTMAN, WEINBERG & REIS CO., L,.P.A.,
436 Seventh Avenue, Suite 1400 Pitr.sburgr
And that the last known address of the D
BROOKE A BECK
403 GLENN AVE
BOILING SPRGS, PA 17007
mbrodt,42524
endant. i s
~I~. oo Po a~`I
~* ~
~~ a5o~t7
Na~ee Mo~,~le~
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
BROOKE A BECK
Defendant
Case No. 10-5685 CIVIL TERM
IMPORTANT NOTICE
TO:
BROOKE A BECK
403 GLENN AVE
BOILING SPRGS, PA 170h071 /~
Date of Notice: ~ t V
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 ONGE, IF YOU DO NOT HAVE A LAWYER, GO TO OR
TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A
LAWYER.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION
ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA. 17013
{717) 249-3166
WELTMAN, WEINBERG &REIS CO., L.P.A.
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
8543832 A P!T T4S
DISCOVER BANK
Plaintiff
vs.
BROOKE A BECK
IN THE COURT OF COMMON PLr:AS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Civil Action No. 10-5685 CIVIL 'T'ERM
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that th following Order of: Judgment
was entered against you on L~`~_ _ __ _ _
(xx) Assumpsit Judgment in the amount of $4443.87 plus costs.
( ) Trespass Judgment in the amount of $ plus costs.
( ) If not satisfied within sixty (60) days, you r_ motor vehicle
operator's license and/or registration will be suspended
by the Department of Transportation, Bureau of Tra~Fic Safety,
Harrisburg, PA.
(xx) Entry of Judgment of
( ) Court Order
( ) Non-Pros
( ) Confession
(xx) Default
( ) Verdict
( ) Arbitration Award
Prothonotar
By : _ / __ _
PROTHO RY (O DEPUTY)
BROOKE A BECK
403 GLENN AVE
BOILING SPRGS, PA 17007
Plaintiff's address is:
c/o WELTMAN, WEINBERG & REIS CO., L.P.A.,
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434-7955
IN THE COMMON PLEAS COURT OF COMMON PLEAS
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
BROOKE A BECK
Defendant
Civil Action No. 10-5685 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, BROOKE A BECK 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:
BROOKE A BECK
403 GLENN AVE
BOILING SPRINGS, PA 17007
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
Military Status Report
Pursuant to the Service Members Civil Relief Act
Page 1 of 2
Oct-20-2010 07:49:11
~. Last
Name First/Middle Begin Date Active Duty Status Active Duty End Date Service
Agency
BECK BROOKE A 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, NOAH, 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 http://www.defenselink.mil/faq/pis/PC09SLDR.htm1. If you have evidence the
person is on active duty and you fail to obtain this additional Service verification, punitive provisions of
the SCRA may be invoked against you. See 50 USC App. §521(c).
If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a
middle name), you can submit your request again at this Web site and we will provide a new certificate
for that query.
This response reflects active duty status including date the individual was last on active duty, if it was
within the preceding 367 days. For historical information, please contact the Service SCRA points-of-
contact.
httnc~//www.~lmdr. ~~rl mil/anni/ccra/n~nrennrt ~ln 1 fl/fin/7(11(1
I,~equest 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(fj 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:NBN78N3GRU
httnc~//www ~lmrlc.nad .mil/anni/ccra/nnnrennrt rln 1 n/~nnn 1 n
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
-E Pf -1-K
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
Discover Bank
vs.
Brooke A. Beck
X011 FF 10 PM 12: "y.
C()M8ERLAt?0 C0L11 -
OHNNSYLVANIA
Case Number
2010-5685
SHERIFF'S RETURN OF SERVICE
02/04/2011 11:41 AM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on February 4,
2011 at 0950 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies
of the within named defendant, to wit: Brooke A. Beck, in the hands, possession, or control of the within
named garnishee, Members 1 st Federal Credit Union, 1166 Walnut Bottom Road, Carlisle, Cumberland
County, Pennsylvania 17013, by handing to Marisol Barber, Assistant Branch Manager, personally three
copies of interrogatories together with three true and attested copies of the writ of execution and made the
contents there of known to her.
02/04/2011 10:01 AM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on February 4,
2011 at 0950 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies
of the within named defendant, to wit: Brooke A. Beck, in the hands, possession, or control of the within
named garnishee, Sovereign Bank, 17 W High Street, Carlisle, Cumberland County, Pennsylvania 17013,
by handing to Denise Beecher, Customer Service Representative, personally three copies of
interrogatories together with three true and attested copies of the writ of execution and made the contents
there of known to her.
The writ of execution and notice to defendant was mailed on February 8, 2011 to Brooke A. Beck at 403
Glenn Avenue, Boiling Springs, PA 170007.
SO ANSWERS,
February 08, 2011 RON R ANDERSON, SHERIFF
(c; Count, Suite Sherfl. I eieoso`t.
De is Fr eputy
WELTMAN, WEINBERG & REIS CO., L.P.A.
BY: James C. Warmbrodt, Esquire
I.D. No.42524
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
Phone: 412.434.7955
Fax: 412.434.7959
File # 8543832
DISCOVER BANK
vs.
BROOKE A BECK
and
MEMBERS 1 ST FEDERAL CREDIT UNION
SOVEREIGN BANK
Garnishee(s)
Attorney for Plaintiff(s) .....
.
c? __.
T _.4
r.
=r
?,. y., z-
CUMBERLAND County
Court of Common Pleas
NO. 10-5685 CIVIL TERM
PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION
TO THE PROTHONOTARY:
Kindly marked the above matter discontinued and ended as to Garnishee(s), SOVEREIGN
BANK, only.
WELTMAN, WEINBERG & REIS CO., L.P.A.
Y
James Warmbrodt, Esquire
Attorn y or Plaintiff
Sworn to and subscribed
Before me the _-day of FEBRUARY, 2011
NOTARY PUBLIC
1,2L1 ? l G 1414t% G `U rrn bteeq
(? ,? ?` 57100 ?'?? l
Notarial Sail
Sheila G. Bevan, Notary Public
Ross Twp., Allegheny County
toy Commission Expires Nov. 15, 2014
6
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVIA - --r
CIVIL DIVISION
DISCOVER BANK
Plaintiff No. 10-5685 CIVIL TERM
vs. PRAECIPE FOR JUDGMENT AGAINST
GARNISHEE
(MEMBERS IsT FEDERAL CREDIT UNION ONLY)
BROOKE A BECK
Defendant
MEMBERS 1sT FEDERAL CREDIT UNION
SOVEREIGN BANK
Garnishee
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
MATTHEW D. URBAN, ESQUIRE
PA I.D.#90963
Weltman, Weinberg & Reis Co., L.P.A.
1400 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#8543832
f J OVh&W
30
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
BROOKE A BECK
Defendant
MEMBERS I ST FEDERAL CREDIT UNION
SOVEREIGN BANK
Garnishee
Civil Action No. 10-5685 CIVIL TERM
PRAECIPE FOR JUDGMENT AGAINST GARNISHEE
TO THE PROTHONOTARY:
Kindly enter Judgment against the Garnishee, MEMBERS I ST FEDERAL CREDIT UNION, in the amount
of $407.95, which is less than Defendant owes to Plaintiff and which amount Garnishee has admitted owing to the
Defendant, in answers to Interrogatories.
WELTMAN, WEINBERG & REIS CO., L.P.A.
MATTHEW D. URBAN, ESQUIRE
PA I.D.#90963
Weltman, Weinberg & Reis Co., L.P.A.
1400 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#8543832
I hereby certify that the address of the Plaintiff is:
c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219
And that the last known address of the Garnishee is: 5000 Louise Drive, Mechanicsburg, PA 17055
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
BROOKE A BECK
Defendant
MEMBERS 1 ST FEDERAL CREDIT UNION
SOVEREIGN BANK
Garnishee
Civil Action No. 10-5685 CIVIL TERM
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
( ) Defendant
(xx) Garnishee
You are hereby notified that the
following Order or Judgment was
entered against you on 3/q/11
(xx) Assumpsit Judgment in the amount
of $407.95 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
( ) Default
( ) Verdict
( ) Arbitration
Award
Prothonotary
BY
PROTHONOTARY (OR DEPUTY)
Members 1st Federal Credit Union
5000 Louise Drive
Mechanicsburg, PA 17055
st ?Gq 3 S 2_
MEMBERS 1St
FEDERAL CREDIT UNION
February 9, 2011
Matthew D Urban, Esq.
436 Seventh Ave
Pittsburg Pa 15219
RE: Writ of Execution for Brooke A Beck
Dear Mr. Urban:
A search of our records has revealed one (1) checking account and one (1) savings account
bearing the name Brooke A Beck with an address of 403 Glenn Ave, Boiling Springs, PA 17007.
The checking account reflects an available balance of $707.94. The savings account reflects an
available balance of $.01. Pursuant to the writ, all funds in the aforementioned accounts have
been frozen and the accounts have been restricted from any further activity.
Pursuant to Rule 3111.1 of Title 231 as promulgated and made effective on April 1, 2007, the
total balance of both accounts exceeds the general monetary exemption under 42 Pa. C.S. § 8123
and are therefore attachable. The full amount of the attachable funds is contained in the
interrogatories as filed with the Cumberland County Prothonotary.
Since the funds contained in these accounts are attachable, and the accounts have been frozen
and restricted from any further activity, no additional funds will be available for attachment.
Should you have any questions or need any additional information, feel free to contact me at
(800) 283-2328, ext. 6353.
Sincerely,
Jody L Burkholder
Deposit Operations Analyst
5000 Louise Drive • P.O. Box 40 • Mechanicsburg, Pennsylvania 17055 • (800) 283-2328 0 wwwmemberslst.org
y ?.
I
RECEIVED
FEB 0 4 2011
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION RECEIVE®
FEB 8 2011
DISCOVER BANK
Plaintiff No. 10-5685-CIVIL TERM
vs. INTERROGATORIES IN ATTACHMENT
MEMBERS 1sT FEDERAL CREDIT UNION
SOVEREIGN BANK
BROOKE A BECK
Defendant
C C=)
and ?? t =--n
=;0
e
MEMBERS 1 ST FEDERAL CREDIT UNION ,
CA ?=
SOVEREIGN BANK co
o 4 '
o
c
Z•
Z =
Garnishees o
FILED ON BEHALF OF: C-)
?' C )
-
CC)
COUNSEL OF RECORD OF
THIS PARTY:
Matthew D. Urban, Esquire
PA I.D. #90963
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#8543832
I
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
BROOKE A BECK
Defendant
and
MEMBERS 1 ST FEDERAL CREDIT UNION
SOVEREIGN BANK
Garnishees
Civil Action No.: 10-5685-CIVIL TERM
TO: Members I" Federal Credit Union Suggested Reference No.: XXX-XX-6532
321 York Road
Carlisle, PA 17013
Sovereign Bank
269 Penrose Place
Carlisle, PA 17013
RE: BROOKE A BECK
403 GLENN AVE
BOILING SPRINGS, PA 17007
IMPORTANT NOTICES TO GARNISHEE!
A. You are required to file answers to the following interrogatories within twenty (20) days after
service upon you. Failure to do so may result in Judgment against you.
B. Herein, the word "defendant" means any one or more of the defendants against whom the writ of
Execution is issued.
C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to
attachment which is then in the hands of the garnishee, it also attaches all property of the defendant which comes
into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For example, the
resultant liability of a Garnishee-Bank would not be measured by the balance in the debtor's account, either at the
time of service of the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited
and withdrawn during the intervening period.
INTERROGATORIES IN ATTACHMENT
1. At the time you were served or at any subsequent time did you owe the defendant any money or
were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money
or were liable to him for any reason (including funds on deposit for checking or savings accounts and certificates of
deposit)?
nO
la. If the answer to Interrogatory I is in the affirmative, state the following: the amount
of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof;
the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written
instruments and the present location of each of such instruments; the amount or amounts that defendant claims or
claimed that you owe or owed to him; and the nature and amount of each of such liabilities.
n1G.
2. At the time you were served or at any subsequent time was there in your possession, custody or
control of yourself and one or more other persons any property of any nature owned solely or in part by the
defendant.
O
3. At the time you were served or at any subsequent time did you hold legal title to any property of
any nature owned solely or part by the defendant or in which defendant held or claimed any interest?
Q
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?
00
5. At any time before or after you were served, did the defendant transfer or deliver any property to
you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof?
Y D
6. At any time after you were served did you pay, transfer, or deliver any money or property to the
defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the defendant
against you?
1(1 V
7. If you are a bank or other financial institution, at the time you were served or at any subsequent
time did the defendant have funds on deposit in an account in which funds are deposited electronically on a
recurring basis and which are identified as being funds that upon deposit are exempt from execution, levy or
attachment under Pennsylvania or federal law? If so, Identify each account and state the reason for the exemption,
the amount being withheld under each exemption and the amount of funds in each account, and the entity
electronically depositing those funds on a recurring basis. 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 oft the general monetary exemption under 42 Pa.C.S. § 8123? If
so, identify each account. y?,??(q q q SaV f n T T0,61 C k er_ K i n ?, 5 7 ,q 4
5 - 5d , 0 o vxessi or' -(' t
l
9. If the answer to Interrogatory 1 is in the affirmative, state the date the sheriff served these
interrogatories on this institution. f) r
10. If the answer to Interrogatory I is in the affirmative, state the date the written instrument, checking
or savings account, certificate of deposit, or other funds were frozen, restricted, or otherwise put on hold by this
institution. 1 1
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?
Y\`4-
12. If the response to Interrogatory 11 is in the affirmative, state the amount of non-exempt funds on
deposit in the account. V) k
WELTMAN, WE ERG & REIS CO., L.P.A.
By:
Matthew D. Urban, Esquire
PA I.D. 490963
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#8543832
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating
to unswom falsifications to authorities, that he/she is Tania S. Young
(Name)
Deposit Operations Analyst of Members 1st Federal Credit Union
(Title)
(Company)
garnishee herein, that he/she is duly authorized to make this verification, and the facts set
forth in the foregoing Answer to Interrogatories are true and correct to the best of his/her
knowledge, information and belief.
U
(SIGNATU ) 0
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No. 10-5685 CIVIL TERM
BROOKE A BECK .y
Defendant - a
MEMBERS 1 ST FCU, - 7k
Garnishee CD
PRAECIPE TO REISSUE & AMEND WRIT OF EXECUTION tv
c4
TO THE PROTHONOTARY:
Kindly issue a Writ of Execution in the above matter...
1. directed to the Sheriff of CUMBERLAND County:
2. against BROOKE A BECK, Defendant
3. against MEMBERS 1sT FCU, Garnishee
4. Judgment Amount $ 4443.87
Less payments of $ 407.95
Interest $ 132.08
Costs $
SUBTOTAL: $ 4168.00
Costs (to be added by Prothonotary): $
WELTMAN, WEI G & 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
QmA S160b Pd q44
0K4Cs171,'p3
WRIT OF EXECUTION and/or ATT CHMENT
1A%ek&6 olna R. 4S14 ed
COMMONWEALTH OF PENNSYLVANIA) NO 10-5685 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s)
From BROOKE A. BECK AT 403 GLENN AVE., BOILING SPRINGS, PA 17007
(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 MEMBERS 1sT FEDERAL CREDIT UNION AT 321 YORK ROAD, CARLISLE, PA 17013
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof;
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $4, 1 la$• 00
Interest $60.63
Atty's Comm %
Atty Paid $176.40
Plaintiff Paid
Date: 1/28/11
L.L. $.50
Due Prothy $2.00
Other Costs
David . Buell, Proth notary
(Stal)
By:
Deputy
REQUESTIN(7 PARTY:
Name MATTHEW D. URBAN, ESQUIRE
Address: WELTMAN WEINBERG AND REIS CO, L.P.A.
1400 KOPPERS BUILDING
436 7TH AVE.
PITTSBURGH, PA 15219
Attorney for: PLAINTIFF
Telephone: 412-434-7955
Supreme Court ID No. 90963
WRIT OF EXECUTION and/or ATTACHMENT
4
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 10-5685 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s)
From BROOKE A. BECK AT 403 GLENN AVE., BOILING SPRINGS, PA 17007
(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 MEMBERS 1sT FEDERAL CREDIT UNION AT 321 YORK ROAD, CARLISLE, PA 17013 AND
SOVEREIGN BANK AT 269 PENROSE PLACE, CARLISLE, PA 17013
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof,
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $4,443.87 L.L. $.50
Interest $60.63
Atty's Comm % Due Prothy $2.00
Atty Paid 5166.40 Other Costs
Plaintiff Paid
Date: 1/28/11
David D. ell, Prothonotary
(Seal) By: -
Deputy
REQUESTING PARTY:
Name MATTHEW D. URBAN, ESQUIRE
Address: WELTMAN WEINBERG AND REIS CO, L.P.A.
1400 KOPPERS BUILDING
4367 TH AVE.
PITTSBURGH, PA 15219
Attorney for: PLAINTIFF
Telephone: 412-434-7955
Supreme Court ID No. 90963
TRUE COPY FROM RECORD
In Testimony whereof, I here unto set my hand
and the seal of said I rt at Carlisle, Pa.
TMsdayof,(L ? ,20 Ir
Prothonotary
G 4J&
.0-, SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff ° i
?°
Jody S Smith
Chief Deputy 1"Y-425 Z5 A`
Richard W Stewart
r
Solicitor .?? 'U I8BL i'qD UIL11?r';' y
PENNSYI..?At IA
Discover Bank
Case Number
vs.
Brooke A. Beck 2010-5685
SHERIFF'S RETURN OF SERVICE
02/04/2011 11:41 AM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on February 4,
2011 at 0950 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies
of the within named defendant, to wit: Brooke A. Beck, in the hands, possession, or control of the within
named garnishee, Members 1st Federal Credit Union, 1166 Walnut Bottom Road, Carlisle, Cumberland
County, Pennsylvania 17013, by handing to Marisol Barber, Assistant Branch Manager, personally three
copies of interrogatories together with three true and attested copies of the writ of execution and made the
contents there of known to her.
02/04/2011 10:01 AM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on February 4,
2011 at 0950 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies
of the within named defendant, to wit: Brooke A. Beck, in the hands, possession, or control of the within
named garnishee, Sovereign Bank, 17 W High Street, Carlisle, Cumberland County, Pennsylvania 17013,
by handing to Denise Beecher, Customer Service Representative, personally three copies of
interrogatories together with three true and attested copies of the writ of execution and made the contents
there of known to her.
The writ of execution and notice to defendant was mailed on February 8, 2011 to Brooke A. Beck at 403
Glenn Avenue, Boiling Springs, PA 170007.
01/23/2012 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: $142.53
January 23, 2012
SO ANSWERS,
RON R ANDERSON, SHERIFF
WRIT OF EXECUTION and/or ATT CHMENT
Amet?f&6 0ma ¢•e-;ssues
c COMMONWEALTH OF PENNSYLVANIA) NO 10-5685 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s)
From BROOKE A. BECK AT 403 GLENN AVE., BOILING SPRINGS, PA 17007
(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 MEMBERS 1sT FEDERAL CREDIT UNION AT 321 YORK ROAD, CARLISLE, PA 17013
GARNISHEE(S) as follows:
and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from
paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant
(s) or otherwise disposing thereof,
(3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession
of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garnishee and is enjoined as above stated.
Amount Due $4; t (pg• 00
Interest 560.63
Atty's Comm %
Atty Paid $176.40
Plaintiff Paid
Date: c I ??•?
L.L. $.50
Due Prothy $2.00
Other Costs
- '= sl",
David. Buell, Proth notary
(S jai)
REQUESTING PARTY:
Name MATTHEW D. URBAN, ESQUIRE
By:
Address: WELTMAN WEINBERG AND REIS CO, L.P.A.
1400 KOPPERS BUILDING
436 7TH AVE.
PITTSBURGH, PA 15219
Attorney for: PLAINTIFF
Telephone: 412-434-7955
Supreme Court ID No. 90963
Deputy
TRUE COPY FROM RECORD
In Testimony whereof, I here unto set my hand
and the? - I of said Court at Carlisle, Pa.
This =day of 20 1 _
Prothonotary
Q??u1t
-ws
}
;,
?'?? ? - _, S , ? i
°? ??.
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Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
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Discover Bank
vs. Case Number
Brooke A. Beck 2010-5685
SHERIFF'S RETURN OF SERVICE
05/13/2011 10:52 ANI - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on May 13,
2011 at 1047 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies
of the within named defendant, to wit: Brooke A. Beck, in the hands, possession, or control of the within
named garnishee, Members 1 st Federal Credit Union, 1166 Walnut Bottom Road, Carlisle, Cumberland
County, Pennsylvania 17013, by handing to Ashley Hock, Customer Service Representative, 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 May 17, 2011 to Brooke A. Beck at 403
Glenn Avenue, Boiling Springs, PA 17007.
01/23/2012 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: $87.66 SO ANSWERS,
January 23, 2012 RON R ANDERSON, SHERIFF
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