HomeMy WebLinkAbout10-5698
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CUMKf:hL*1.!1D COUNT
MMYLVANIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff No: to -,5&qB Civi! Term
vs.
COMPLAINT IN CIVIL ACTION
HEN T NGO
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
08543900 C A Pit CXC
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40.00 PQ ATN
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No
HEN T NGO
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:
HEN T NGO
7 FORGEDALE DR
CARLISLE, PA 17015
3. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXX3815 .
4. Defendant made use of said credit card and has a current balance
due of $7143.97 , 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
29.990% per annum on the unpaid balance from July 08, 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 , HEN T NCO individually , in the amount of
$7143.97 with interest at the rate of 29.9906 per annum from July 08,
2010 plus attorneys' fees of $125.00 , and costs.
fames c.
WELTMAN,
436 SeVE
Pittsbu
(412) 4
FAX: 4 2
085439 C
This law firm is a debt collector attem
our client and any information obtained
rmbroc[t, 42524
INBERG & REIS CO., L.P.A.
Avenue, Suite 1400
PA 15219
955
38-7130
A Pit CXC
to collect this debt for
be used for that purpose.
DISCOVER So Now Balance
30 SDSNSAOI 0005222
HEN NGO
7 FORGEDALE DR
CARLISLE PA 17D15-43R9
[Minimum Payment Due Account Number ending in 3815
753.00 Enter Amount Enclosed Below
Payment Due Date
July 25, 2010 $
HIBIT Go paperless and make your account
EX information more secure with password-
protected statements only you can access.
Learn more at discover
I .corrJpapetiess.
PO BOX 6103 111 11 illegessillili of 19111111
CAROL STREAM IL 60197-6103
Go Address, to vvww.Dilisca telephone
or onec print change in space above hilrrlluutrlllllnlnallllurtrllllnnrllrllt,utllulnll
.
000001986458203475211000000000000000175300
Opening Date: June 6, 2010 - Closing Date: June 30, 2010
Discover More Card Account Summary
I Account number ending in 3815
Previous Balance $7,143.97
Payments And Credits 7,143.97
Purchases + 0.00
Balance Transfers + 0.00
Cash Advances + 0.00
Interest Charged + 0.00
Fees Charged + 0.00
New Balance ?p.00
See Interest Charge Calculation section following
transactions for detailed APR information
Credit Line $5,800.00
Credit Line Available $0.00
Cash Advance Credit Line $1,500.00
Cash Advance Credit Line Available $0,00
Cashback Bonuse Anniversary Month
October
Opening Cashback Bonus Balance $ 0,00
New Cashback Bonus This Period + 0.00
Cashback -B.. 9.6. $ 0.00
To barn more, log in at www.D6cover.com and selea Rewards
Payment Information
New Balance $0.00
Minimum Payment Due $1,753.00
Payment Due Date July 25, 2010
Lam Payment 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
29.991% variable.
Manage Your Account Online at www.Discover.com
• Securely access statements and free online tools, pay bills
online and track and view all transactions simply and easily
• Make your money worth moreSM -find easy ways to earn
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 wvvw.Discover coin
2. Call 1-800-DISCOVER (1-800347-2683)
Please have your Discover®card available.
3. Write to us at Discover, PO Box 30943,
Salt Lake City, UT 84130
For TDD (Telecommunications Device for the Deal)
assistance, please call 1-800-347-7449.
Transactions
Trans. tePuts
Payments and Credits Jun :30 Jun 30 INTERNAL CHARGE-OFF $ -7,143.97
Fees TOTAL FEES FOR THIS PERIOD $ 0.00
Interest Charged TOTAL INTEREST FOR THIS PERIOD $ 0.00
2010 Totals Year-to-Date
TOTAL FEES CHARGED IN 2010 $ 273.00
TOTAL INTEREST CHARGED IN 2010 971.49
k*Wn*]Charge Calculation
Your Annual Percentage Rate (APR) is the annual interest rate on your account.
Currant Bit' Period: 25 ANNUAL PERCENTAGE BALANCE SUBJECT TO INTEREST CHARGE
?g days RATE (APR) INTEREST RATE
Purchases 29.99% V S0 $0
Cash Advances 29.99% V $0 s0
V = Variable Rate
Aaanronw Important Irtormahon -
Important Information. IF there :s more than one page to this billing statement, see the bock of each page for addkionol important Information
-nnoea Oft reverse sltle. - ---
_ DlSC*VER
l
See your Cardmember Agreement. Your Cardmember Agreement contains all the terms of your Account
lost or stolen cards. Report immedwrolyl Call 1-800-347-2683.
What To Do If You Think You find A Mistake On Your Statement
If you think tore is on error on your statement, write ious at Discover, PO Box 30,121, Sall Fake City, UT 841300421
In your letter, give us the following information
Account information: Your rwme and account number
Dollar amount The dollar amount of the suspected error
Description of Problem: R you think there is an error on your bill, describe what you believe is wrong and why you believe ii is a mistake
You must contact us within 60 days after The error appeared on your sement
a
You muss notify us of any potential errors in writing You may call us, b
ut if you do we are not required to investigate any potential errors and you may have to
pay the amount in question
While we investigate whether w nor there has been an error, the following are true
We cannot ley to collect the amount in question, or report you as delinquent on that amount
The charge in question may remain on your statement, and we may continue to charge you interest on that amount But, if we determine shat we made o
mistake, you will not have to Foy the amount in question or any interest w other fees related to that amount
While you do not have to pay the amount in question, you arc responsible For the remainder of your balance
We can apply any unpaid amount against your credit limb
Your Rights B You Are Dissatisfied With Your Credit Card Purchases
K you are dissofisfied with the goods a services that you have purchosed with your credit card, and you have tried in good faith to correct the
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 slate or within 100 miles of your current mailing address, and the purchase price trust have
been more than $50 (Note: Neither of These arc necessary IF your purchase was based on on ocivertisemenl 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 tor the purchase Rurhovss made with cash advances from an ATM or with a check That accesses your _
credit card account do not qualify
3 You must not yet have fully paid far The purchase "
If of of the criteria above ore met and you are still dssatsfied with the purchase, contact us n writing at Discover, PO Box 30945,
Salt fake City, UT.8413009,15 to
O
While we investigate, to same rules apply to Ike disputed amount as discussed above Alter we finish our investigation, we will Tell you our to
decision At That point, iF we think you owe an amount and you do not pay we may report you as delinquent z
PaymsfttS. Send only your payment and the lop portion of this statement in the envelope provided Do not send cash By sending your check as described o
above, you authorize us to use information on your check to make on electronic fund transfer from your account at the Financial institution indicated on your
clock cr to process the pa rent as a check transaction If payment is processed as an electronic Fund transfer, the transfer will be for the amount of" check.
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unds maybe withdrawn from your account as soon as the same day we receive u°h
your payment, and you will not receive your check back from your financial institution
The processing of your payment may be delayed B you send cash, correspondence or other items with your payment, if you send the payment to any other
address or a you use an envelope other than the one provided Payments received in peope r Form four
rocessin
facilit
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Ise credited to your Account as of That day Payments received of our processing facility alter 5PM local sine will be credited to your Account as of to next
day If you have misplaced your envelope, send your payment to Discover, PO Box 6103, Carol Stream, IL 60 1 97-6103 Pease allow 7.10 days for delivery x
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if your payment is returned unpaid, we reserve the right to resubmit it as an electronic debit
You can pay your minimum payment or a greater amount over the Telephone, and you can set up automatic payments. Call us of I-BM347.2683 You will
need This statement and your bank account information You must ensure That sufficient Funds are available in your bank account, and all transactions must
comply with U S. low You will be asked to provide the First 5 digits of your account statement ZIP code By entering Those numbers as your electronic
signature, you will be agreeing to this authorizolion to allow us and your bank to deduct each Payment you authorize from your bank account, and to initial&
debtt or credit entries to your bank account, as applicable, to correct an error in the processing of such payment You must lei us the amount of each payment
or you can seed an amount such as the Minimum Payment Due or The New Balance on each statement You can cancel o payment, however we must receive
notice at least three business days in advance of the scheduled payment You may notify us by phone at 1.800347-2683 or by mail at die address listed in the
pdevious paragraph If your payments vary in amount, we will Tell you on, each monthly ssaTemenl when your payment will be made and how much it will be
Y
our automatic payment amount may be less Than indicated on the mon kly statement bored on credits or payments applied during the bdkng cycle
Credit Reporting. We may report information about your Account to credit bureaus late payments, missed payments, or other defaults on your Account
my be reflected in your credit report We normally report to status and payment history of your Account to credit reporlinq ogencies each month if you
believe that our report is inaccurate or incomplete, plea rite us at the Following address. Discover, PO Box 15316, Wilmington, DE 19850-5316 . Plow
indicate your name, address, home Telephone numbs and Account number
Paying Interest: We begin to impose Interest Charges on all transactions from the Transaction Dole for the transaction shown on your billing slowere I,
unless a transaction u posted to your Account offer the close of the billing period in which it occurs, in which case we begin to impose interest charges an tat
transaction fro
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billi
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a your Account We continue to impose Interest Charges until The date you pay your
ens re New Balance shown on your billing statement by making payments or receiving credits B you paid The New Balance on
our
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by the Payment Due Dale shown on that billing statement, we will not impose Interest Charges on new purchases, That is, purchases firs oppsaring on the
b
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current
il
ing statement, many portion of es new purchase, paid by "Payment Due Date on your current billing statement We call This the "grace period - it
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Th
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an
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ere is no grace period on balance transfers or cash advances As more fully described in the section of your Cardrrember
A
reement filled `How We A
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ccount
ase
on The APR applicable to the balance of each transaction
category This means that t you do not pay the New Balance on the current billing statement by The Payment Due Date shown on that baling statement, then,
depending on the amount of your payment and the APRs on other balances, you may not gel a grace period on new purchases
Minimum Interest Charge. We will charge you a minimum Interest Charge of $ 50 for any billing period in which interest Charges of less than $.50
would otherwise be imposed
Annual Fee. If your Account has an annual fee, it will be billed at the beginning of each anniversary year your Account is open The amount of the lee
appears on the statemenl when the Fee fs billed The annual lee is not refundable unless you notify us that you wish to close your Account within 30 days of the
mailing or delivery date of the statement on which to fee is billed You will receive this refund even t you use your Cord during Thal period
How We Calculate Interest Charges - Daily Valance Method rnduding current transisdions)e We figure Interest Charges for each billing
period To do this.
We calculate your Interest Charges separately for each balance subject to different Terms (for example, standard purchases, standard cash
advances and each purchase
balance transfer and cash adv
n
b
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b
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,
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a
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terms) We refer to these balances as
Iransachon categories
We figure the 'daily balance' for each transaction category To get the 'daily bolomiin we take the beginning balance for each day, add any
new transactions and fe
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any
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arges accrue
on t
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s duly balance W en subtract any credi
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make other adjustments (including those adjustments required in the section Rlled'Poying Interesl'I In calculWing Ilhe daily balance for the first
day of the billing period, we consider the 'previous day's doily balance' to have been your balance on the last day of your previous billing
period This gives us the doily balance for each transaction category
We Figure the Interest Charges on your Account by multiplying to daily balance For each transaction category by its daily periodic rate, for each
day in the billing period
The total Interest Charges for the billing period are the win of the daily Interest Charges For each transaction category For each day during that
baling period
When we calculate daily balances, we add a new transaction as of the Transaction Dote shown on your billing statement, unless the fransaclion is posted to
Account after the close of the billing period in which a occurs, in which case the transaction veal be added to Oro daily balance as of the first day of to
r
ig period in which it is posted to your Account All fees charged to your Account are added to the standard purchase transaction category with the
exception of Cash Advance Fees which are added to the applicable cosh advance transaction category and Balance Transfer fees which are added to The
appli-blc balance transfer transaction category
""SOOncy Fee: 2% of The U S dollar amount of each purchase made in a foreign currency
Penally APRs: Each time you fail to make a payment when due, we may, in accordance with applicable law, (i) Terminate The availability of any
introductory/promotional APRs on new transactions, and (it) increase your APRs for new transactions to variable Penalty APRs which will be determined by adding
up to on additional 5 pwcenage potnh to the otherwise applicable APR. Your Penalty APR is determined baud on your creditworthiness and other Factors such
as your current APRs, and your account history If your APRs for new transactions are increased for a late payment, The PenaltyAPRs will apply indellnibly
For TDD (Telecommunications Device for the Deaf) assistance, please call 1$00-347-7449.
Discover may monitor and/or record Telephone calls between you and Discover representatives for quality assurance purposes
The DiscovertD cord is issued by Discover Bank, Member FDIC OITBK172
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# 8543900
Hen T. Ngo
6011002162033815
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ya "id
~~ io 1 ~J Q~~ $~ J~
CUP~hpE~il~SYt.~I~'~ NTY
Discover Bank
vs. Case Number
Hen T. Ngo 2010-5698
SHERIFF'S RETURN OF SERVICE
09/10/2010 06:43 PM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on September
10, 2010 at 1843 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Hen T. Ngo, by making known unto Brandon Lord, adult in charge at 7 Forgedale Drive,
Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to him
personally the said true and correct copy of the same.
SHERIFF COST: $33.40
September 13, 2010
/ ~_.
DENNI RY, DEPU
SO ANSWERS,
RON R ANDERSON, SHERIFF
r'
~~
HAROLD S. IRWIN, 111, ESQUIRE
ATTORNEY ID NO. 29920
64 80UTN PITT STREET
CARLISLE PA 17015
(T17) 243.6090
ATTORNEY FOR DEFENDANT
DISCOVER BANK,
PlaintMf
vs.
HEN T. N60,
Defendant
f11~~~'2~ P~ ~: ~ t:
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: IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NO. 2010 -5698 CIVIL TERM
IN ASSUMPSIT
NOTICE TO PLEAD
TO:
MATTHEW URBAN ESQ
WELTMAN WEINBERG 8~ REIS CO., LPA
436 7T" AVE 1400 KOPPERS BLDG
PITTSBURGH PA 15219
YOU ARE HEREBY NOTIFIED that you must plead to the within NEW MATTER within twenty
(20) days after service, or a default judgment may be~entered against you.
HAROLD S. IRWIN, III
Attorney For Defends
64 South Pitt Street
Carlisle, Pennsylvania 17013
717-243-6090
Supreme Court I.D. No. 29920
,~~
w
DISCOVER BANK,
Plalntlif
vs.
HEN T. N60,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL ACTION -LAW
NO. 2010 - 5698 CIVIL TERM
IN ASSUMPSIT
DEFENDANT'S ANSWER TO PLAINTIFF'S COMPLAINT
NOW, comes the defendant, HEN T. NGO, by her attorney, Harold S. Irwin, III, Esquire, and responds to
plaintiffs complaint as follows:
1. The averments of paragraph one of plaintiffs complaint are admitted.
2. The averments of paragraph two of plaintiffs complaint are admitted.
3. The averments of paragraph three of plaintiffs complaint are admitted.
4. The averments of paragraph four of plaintiffs complaint are admitted in part and denied in part. It
is admitted that defendant made some use of the card. The remaining averments are denied for the
reasons stated in defendants new matter below and by reason that after reasonable investigation
defendant is without facts sufficient to form a belief as to the truth of the averments and proof thereof at
trial is demanded, if relevant.
5. The averments of paragraph five of plaintiffs complaint are conclusions of law to which no
response is required. However, if a response is required, those averments are denied for the reasons set
forth in defendant's new matter below.
6. The averments of paragraph six of plaintiffs complaint are conclusions of law to which no
response is required. However, if a response is required, those averments are denied for the reasons set
forth in defendant's new matter below.
7. The averments of paragraph seven of plaintiffs complaint are denied. On the contrary, defendant
never knowingly agreed to pay attorney fees for plaintiff.
a
8. The averments of paragraph eight of plaintiffs complaint are denied by reason that after
reasonable investigation defendant is without facts sufficient to form a belief as to the truth of the
averments and proof thereof at trial is demanded, if relevant.
9. The averments of paragraph nine of plaintiffs complaint are denied for the reasons stated in
defendant's new matter below.
WHEREFORE, defendant demands that plaintiffs complaint be dismissed and that judgment be entered
in favor of defendant and against the plaintiff.
NEW MATTER
10. Defendant incorporates by reference her responses to plaintiffs complaint, paragraphs one
through nine above, inclusive, as if fully set forth herein at length.
11. Defendant's credit card for the subject account was stolen from her in Baltimore, Maryland.
12. Defendant notified plaintiff that her credit card had been stolen and provided to them the name of
the person who admitted to stealing the card.
13. When defendant notified plaintiff of the theft, she also requested that the account be closed so
that no additional charges could be made on the account.
14. Plaintiff failed and refused to close the account, thereby providing the opportunity to the person
who stole the credit card to continue to run up charges on the account without being properly identified at
the time of his purchases.
WHEREFORE, defendant demands that the complaint be dismissed and that judgment be entered on
behalf of the defendant and against the plaintiff.
IR IN W OFFIC
October 20, 2010
R LD S. IRWIN,111
Attorney for defends t
64 South Pitt Street
Carlisle, PA 17013
717-243-6090
Supreme Court ID No. 29920
VERIFICATION
I verify that the facts contained in the attached answer and new matter are true and correct to the best of
my knowledge, information and belief. I understand that false statements made herein are subject to the
penatiies of 18 Pa.C.S.A. Section 4094, relating to unswom falsfication to authorities.
October 20, 2010
HEN T. NGO
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff, No. 2010-5698
TYPE OF PLEADING:
VS. PLAINTIFF'S REPLY TO NEW TIATTIR
HEN T. NGO, ,
FILED ON BEHALF OF:
Defendant. Plaintiff
COUNSEL OF RECORD OF _
THIS PARTY:
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 # 8543900
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK,
Plaintiff, No. 2010-5698
VS.
HEN T. NGO,
Defendant.
PLAINTIFF'S REPLY TO NEW MATTER
AND NOW, comes the Plaintiff, by and through its counsel, William T. Molczan,
Esquire and Weltman, Weinberg & Reis Co., L.P.A., and files the following Reply to New
Matter:
10. Plaintiff hereby incorporates by reference the averments contained in its original
complaint as if fully set forth herein.
11. After reasonable investigation, Plaintiff has been unable to determine the truth of
the averments contained in Paragraph 11 of Defendant's New Matter and the same therefore are
denied.
12. After reasonable investigation, Plaintiff has been unable to determine the truth of
the averments contained in Paragraph 12 of Defendant's New Matter and the same therefore are
denied.
13. After reasonable investigation, Plaintiff has been unable to determine the truth of
the averments contained in Paragraph 13 of Defendant's New Matter and the same therefore are
denied.
14. After reasonable investigation, Plaintiff has been unable to determine the truth of
the averments contained in Paragraph 14 of Defendant's New Matter and the same therefore are
denied.
WHEREFORE, Plaintiff demands judgment in its favor and against the Defendant in the
amounts demanded in its Complaint.
Respectfully Submitted:
WEL'TMAN, WEINBERG & REIS, CO.,
L.P.A.
By:
William T. Molczan, squire
PA I.D.# 47437
1400 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR# 8543900
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 Pa. C.S. 14904 relating to
unsworn falsification to authorities, that he is an attorney for the Plaintiff herein and makes this
Verification based upon the facts as supplied to his by the Plaintiff because the Plaintiff is outside the
jurisdiction of the court and the Plaintiff's Verification cannot be obtained within the time allowed for the
filing of this pleading; and that the facts and circumstances set forth in this pleading, are true and correct
to the best of his knowledge, information and belief.
William T. Molczan squire
CERTIFICATE OF SERVICE
I certify that I served a true and correct copy of Plaintiff's Reply to New Matter by First
Class Mail, Postage Pre-Paid, on the.,_ day of 2010, upon the following:
Harold S. Irwin, III, Esquire
64 South Pitt Street
Carlisle, PA 17013
By:a •°? _- --
William T. Molc ,Esquire