The URL can be used to link to this page

Home My WebLink About10-6114FiDI'BTAR`?' rL Pj I0S'"P 23 A'fMII:3t ?"?D'c7RL AND C0UIf4TY R ?'SYLVANIA IN T'HE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYI.VAMA CIVIL DIVISION DISCOVER BANK Plaintiff VS. ROSALIND G GRAEFF Defendant(s) No. 10 - (p114 C?vc l TeM COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD 01 THIS PARTY: James C. Warmbrodt, Esquire PA I. D. #42524 WELTMAN, WEINBERG & REIS CO.. L..P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR#8017802 Q 0a• DO PO IkTry ofq"3,0Z P-# 08 W03 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs Civil Action No. ROSALIND G GRAEFF Defendant(s) COMPLAINT IN CIVIL ACTION 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 FARE A LAWYER, THIS OFFICE. MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ON AGENICES THAT MAY OFFER LEGAL_SERVICFS TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff is a corporation with offices at 6500 NEW ALBANY ROAD, NI:W ALBANY. 01 -143054. 2. Defendant(s) is/are adult individual(s) residing at the address listed below: ROSALIND G GRAEFF 1770 PEYTON RANDOLPH COURT NEW CUMBERLAND, PA 17070 3. Defendant(s) applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXX6931. 4. Defendant(s) made use of said credit card and has currently a balance due of 52.741.53, as of September 13, 2010. 5. Defendant(s) is/are 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 29.99% per annum on the unpaid balance from September 13, 2010. A true and correct copy of Plaintiff's Statement is attached hereto. marked as Exhibit "1" and made a part hereof. 7. Plaintiff avers that the Agreement between the parties provides that Defendant(s) will pay Plaintiffs attorneys' fees. 8. Plaintiff avers that such attorneys' fees will amount to $125.00. 9. Although repeatedly requested to do so by Plaintiff, Defendant(s) has/have willfully failed and/or refused to pay the balance due to Plaintiff. WHEREFORE, Plaintiff prays for Judgment in its favor and against Defendant(s). ROSAI-IN I) G GRAEFF individually, in the amount of $2.741.53 with continuing interest thereon at the rate of 29.99'% per annual from September 13, 2010 plus attorneys' fees $125.00, and costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS. CO., L.P.A. rodt, Fsquire James C. f+71'- PA I.D. #4 24 WELTM WEINBERG & REIS CO., L.P.A. 1400 Ko p rs Building 436 Se en Avenue Pittsb g , PA 15219 (412)43 -7955 WV?R'#:8017802 VI*j%wk" 11 ? 16 1% $2,741.53 i $2,741.53 Enter Amount Enclosed Below CARD Payment Due Date DUE IMMEDIATELY 08 SDSN6A01 0004621 GRAEFF Will your payment get to us on time? Pay ROSALIND your bill online and your payment can be 1931 S FORGE RD made to your account on the same day. Visit PALMYRA PA 17078-8964 Discover.com/payments today. PO BOX 6103 IIl.rrllr..l lr..lr.l"'I'II CAROL STREAM IL 60197-6103 Address, e-mail or telephone change? Print change in space above, or go to Discover.com. Print your e-mail address to receive important Account information and special offers. 000001986458781593757027415 300000000274153 Discover More Card Account Summary Closing Date: November 8, 2009 page 1 of 1 Account number ending in 6931 Previous Balance $2,741.53 Payment Due Date December 3, 2009 Payments And Credits 0.00 Minimum Payment Due $2,741.53 Purchases + 0.00 00 0 Credit Limit $2,000.00 Cash Advances . + Credit Available $0.00 Balance Transfers + 0.00 Cash Credit Limit $0.00 Finance Charges + 0.00 Cash Credit Available $0.00 New Balance = $2,741.53 Cashback Bonus® Opening Cashback Bonus Balance $ 0.00 New Cashback Bonus This Period + 0.00 Cashback Bonus Balance $ 0.00 Cashback -Banus9 Anniversary Date: February 8 1. Visit Discover.com to pay your bill for no cost, view our How Can We Help You? latest Account information, earn and redeem rewards and more It's your choice - 3 ways to help 2. Call 1-800-DISCOVER (347.2683) For fast, easy self-service options or to speak with a Customer Service Account Manager Please have your Discover Card available. 3. Write us at Discover Card, PO Box 30943, For TDD (assistance For hearing impaired) see reverse side Salt Lake City, UT 84130 'Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence. Information For You Your Account is overlimit. While we are permitted under the Cardmember Agreement to charge you an Overlimit Fee, we have chosen not to do so at this time. We reserve the right to do so if, as of the close of a billing period, your outstanding Account balance exceeds your Account credit limit. See the Overlimit Fee section of the Cardmember Agreement for details. CA 7? -1 Finance Charge Summary Nominal Transaction Average Daily ANNUAL ANNUAL Periodic Fee Daily Periodic PERCENTAGE PERCENTAGE FINANCE FINANCE GES Balances Rates RATES RATES CHARGES CHAR current billing period: 8 days Purchases $0 0.08216% 29.99% V 29.99% $0 $0 Cash Advances $0 0.08216% 29.99% V 29.99% $0 $0 The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above. lagrortant Information. If there is more than one page to this billing statement see the back of each page for additional important information . See your Cardmember Agreement. Your Cardmember Agreement contains all the terms of your Account Lost or stolen cards. Report Immediately! Call 1-800-947-2889. o BIBIno R?hts Summary. In Case of Errors or Questions About Your trans ?cUOTI on gill: It u think wur bill Is wrong, or if You n d more information about a your bill, write to us on a separate sheet of papa at 815cov?r°Card- PoBox 30421 Saii Lake City. U? 84130-0421 as soon as posgible. We must dear from you no later an 60 do -after We sent you the firsf bill on which fhe error or rbDlem ?sDut dolngg so wi I not preserve your ri appeared ht I p Sou can t l h l Cl) a g . s. e n your ep one etter, give us thb following information: Ternane and Account number amount of th o o e su5pecled error • Describe the error and explalh, if you can, why you believe there is an error If you need mor i f b . e n a out ormation, describe the item you are unsure You do not have to a an amount in while we are invests aUn , but you are still obligated to DaY the parts of your bill that are not in question. While we Pn%stlUe your quetion, we cannot report you as del?nquerft or take an action to olM th x y c e amount you question. S?cld Rya fa Credit Card Purchases: If u have a Droblem with the quality of Dods or services that you urchased with a credit card, and , Nava Uted In faith to correct the lam with the merchant you may not ?ave to pay the remainln mount due on th 9s or Services. i o s tton only when th e vyo0ouUu have th u hase oHCe was more than ;ba anC the purchase Was made in ? i 1 n l 9 ? vo r ome state or wile o e 10D miles of regaje6 nt of IoraUonobi pa rchase)Merchant or if we mailed you the advertisement for the garods or services, all purchases are covered 4 bf themsou P Send onl o r avment and th to rtion of this statement in the a veto p oV9.4 n ?t send cash. sendin ur ch k as ayut se ?iorr?ie us to use inorrtia Iar on rt as aBrook to eke an ectrauc tur tom your ac cofint at vo inst ration indlq ' tbd on Your check or toprocess the r1? t??L rinanc l If n on. transfer will be for the amount of the check When a infotmet infrom vo a i as an elerctronic nudsd?raavner, the from yo ccou withdrawn ur ant as soon as the same we rer eive ym you wi not day your pa ant and Institution txrr ch u k 1ek fif y . ec bac ro m your nnancial The processin of our pa ment ma be delayed if you sod cash comes ndence or other Items with Your oavment if you send the oa ment to througgh t<riday or env othBi addres or ?f you ae an env loppee other arf the one ?,?,? Papyoments received on or attar 1 PM at our orocessin? faclll Atol?da a weekend or bank Dolida I be p?ted fo You-r-A nt a8 of the next bus I on ness d s nd If ? t t u ? ay e you have misplaced it envei ?e, your payment to DIsC7r Bank, PO eeoox 6T0333 Card SV?m, iL 60197- 103. Please allow 7-1 days fdr delivery If your payme t is return uneai ^we erve the rid t to resubmit it as an electron debit vv vu ua rYUna M I-ouV- 41-16tl3 aOar try mail t the address 11 radio the w`?i"m to Va Sin amuoun we will tell u Indicated on the monthiytstatteement baseedrdn creditsor a ma and haw much ro oma Fc p?amouWt may be less than payments applied during the bill ng cycle. Credit Ring. We ma report information about r account to credit bureaus. Late v cents, missad ments, or other defaults on ur account mva? be tlected ?n yo report s r credit report, We nvpou all the status and oa tf of r ant to credit t ?r1th 1i 33 that ?u is i aNdres wrtfa us t arld Iscover Card, PD x 1 tl,-wri(iriir, 1 each rate or ?E 19650- t ease inc ude your name, , address, in ane , have number and CM num r. no rem rc Finance Charges for each day of the b6jIling pA@vfor WCV' tensed finance arges for each transaction category average Dally Balance) times (days in billing period) times (Daily Periodic Rate). a to the finance charge summary, on Your biilin statement for these amounts.) Then we add up the Periodic Finance Charges for each Io1y to set the total Periodic Finance Char?0ae for your Account The Average Daily Balance is shown as zero if, because of the grace c Finalsce Char a I to the balance in ..4 trans U catedorv. 3a for a 'section category town on you case the the NId F1r?ce Char e. We will charge you a minimum FINANCE CHARGE of $.50 for any billing period in which Periodic Finance Charges of ess tsti $.50 would oth$rwise be Impose. inlyal Fee. If Your Account fill ee It will be billed at th beginning of each anniversary ear our Account is open. The amount of he ee rs n the statem is billed. The annual ea not fucdable unless rr Xotl us that you wish to close your Account vithin 30 tlays of the mailing or delivery ate of the statement on which the fee Is Ilse . You wi receive this refurjd even If you use your Card luring that period. + Seq. '. 2010 4:37PM VERIFICATION No.8261 P. 2/2 The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsifications to authorities, that he/she is NATASHA SZCZ(Name) ACCOUNT MANAGER of DFS SERVICES LLC plaintiff herein, that (Title) (Company) he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief. WWR# 8017802 DFS#6011002687506931 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~4~titU` oC411A~Grp~f,~~t Jody S Smith '~ Chief Deputy - Richard W Stewart Solicitor ~ - ~'~ ~'' ` ""'"` Discover Bank vs. Rosalind G. Graeff Case Number 2010-6114 SHERIFF'S RETURN OF SERVICE 09/27/2010 08:30 PM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on September 27, 2010 at 2030 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Rosalind G. Graeff, by making known unto herself personally, at 1770 Peyton Randolph Court, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $43.30 September 28, 2010 DENNIS F ,DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF -~ cs ~-f v~r- ,J -~,'~ ~~ _ ..~ L ...... .,.~ N D -'. crs -~ C .. f 7E!:. ~,dt. .Y:;. Ft: r-CFF(CE OF TNT f' 0T,-TN0TARY 2010 C .,; 2: 0 9 CUME" 0?J QTY 1A N! A IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: 10-6114 CIVIL TERM VS. ROSALIND G GRAEFF PRAECIPE FOR DEFAULT JUDGMENT 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 08017802 C A Pit ALL Judgment Amount $3025.98 µg8oy(fis oLk DISCOVER BANK Plaintiff vs. ROSALIND G GRAEFF TO THE PROTHONTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Civil Action No. 10-6114 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant ROSALIND G GRAEFF above named, in the default of an Answer, in the amount of $3025.98 computed as follows: Amount claimed in Complaint Less payments / adjustments made Interest on the remaining principal $2741.53 from September 13, 2010 Q the interest rate of 29.9900 Attorney's fees TOTAL $2741.53 $0.00 balance of to November 23, 2010 per annum $159.45 $125.00 $3025.98 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 : N jt: ? James C. r rodt,42524 08017802/C )k Pit ALL Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburg A 15219 And that the last known address of the Dendant is ROSALIND G GRAEFF 1770 PEYTON RANDOLPH COUR NEW CUMBERLAND, PA 17070 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff Case No. 10-6114 CIVIL TERM VS. ROSALIND G GRAEFF Defendant IMPORTANT NOTICE TO: ROSALIND G GRAEFF 1770 PEYTON RANDOLPH COURT NEW CUMBERLAND{, P 170070 Date of Notice: t Ito i YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA. 17013 (717) 249,3166 WELTMAN, WEINBERG & REIS CO., L.P.A. Ma 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 8017802 A PIT H4N IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 10-6114 CIVIL TERM ROSALIND G GRAEFF 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 , ROSALIND G GRAEFF is not in military service. . Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the DMDC does not possess any information indicating that the below individual is in the military service: ROSALIND G GRAEFF 1770 PEYTON RANDOLPH LOUR NEW CUMBERLAND, PA 17070 Affiant further states that the averments contained herein are true and correct to the best of Affiant's knowledge, information and belief and that these averments are made subject to the penalties of 18 Pa C.S.A. Section 4904 relating to unsworn falsification to authorities. Request for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Dec-06-2010 08:00:27 < Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency GRAEFF ROSALIND Based on the information you have furnished, the DMDC does not possess G any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). Olt 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.miUfaq/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. https://www.dmdc.osd.mil/appj/scra/popreport.do 12/6/2010 Request for Military Status Page 2 of 2 More information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:GA I 9PTEJQD https://www.dmdc.osd.mil/appj/scra/popreport.do 12/6/2010 DISCOVER BANK Plaintiff vs. ROSALIND G GRAEFF TO. IN THE COURT OF COy;MON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Civil Action No. 10-6114 CIVIL TERM NOTICE OF JUDGMENT OR ORDER ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order of Judgment was entered against you on I it -(p - ( D (xx) Assumpsit Judgment in the amount of $3025.98 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotarv By: ROSALIND G GRAEFF 1770 PEYTON RANDOLPH COUR NEW CUMBERLAND, PA 17070 Plaintiff's address is: _ii"1 c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 10-6114 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s) From ROSALIND G. GRAEFF AT 1770 PEUTON RANDOLPH COURT NEW CUMBERLAND, PA 17070 (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 SUSQUEHANNA VALLEY FEDERAL CREDIT UNION AT 3850 HARTZDALE DR. CAMP HILL, PA 17011 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 $3,025.98 Interest $23.88 Atty's Comm % Atty Paid $176.30 Plaintiff Paid Date: February 7, 2011 (Sea]) REQUESTING PARTY: Name MATTHEW D. URBAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., L.P.A. L.L. $.50 Due Prothy $2.00 Other Costs avid . B ll, PrWno By: 140 0 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 90963 Deputy FILED-OFFICE of THE PP.OTi ONOTARY al f FEB -1 PM 12' 19 r~UMBEKLAN3 COUNTY PENNSYLyAH" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 10-6114 CIVIL TERM vs. PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) ROSALIND G GRAEFF Defendant SUSQUEHANNA VALLEY FEDERAL CREDIT UNION, Garnishee, v- ?6 4 ltlGD n 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 Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#8017802 PA_11td117S3 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 10-6114 CIVIL TERM ROSALIND G GRAEFF Defendant SUSQUEHANNA VALLEY FEDERAL CREDIT UNION, Garnishee PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: 2. against ROSALIND G GRAEFF, Defendant 1776 P4t4i4i -124alolpt, N &14AA3 &tWWr 000 PA 170?0 3. against SUSQUEHANNA VALLEY FEDERAL CREDIT UNION, Garnishee 2,956, ! ?G?rtzGlGti of hi ni P PO hpA /7a l I 4. Judgment Amount $ 3025.98 Interest Costs SUBTOTAL: $ 23.88 $ 3049.86 Costs (to be added by Prothonotary): $ WELTMAN, ERG & REIS CO., L.P.A. y: Matthew D. Urban, Esquire PA I.D. #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15,219 (412) 434-7955 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 'jkl iI LE Q_t,lFF !I '. ,?? ? ?,i?r,GFr rr Jody S Smith HE ? ?.0T H I?`F i . Chief Deputy Richard W Stewart 2' 7 Solicitor €;UMBERt..A?@ (03UN v PENINSYLVANIA, Discover Bank vs. Rosalind G. Graeff Case Number 2010-6114 SHERIFF'S RETURN OF SERVICE 02/11/2011 12:50 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on February 11, 2011 at 1247 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Rosalind G. Graeff, in the hands, possession, or control of the within named garnishee, Susquehanna Valley Federal Credit Union, 3850 Hartzdale Drive, Camp Hill, Cumberland County, Pennsylvania 17011, by handing to Patricia Sheffer, Receptionist, 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 16, 2011 to Rosalind G. Graeff at 1770 Peyton Randolph Court, New Cumberland, PA 17070. SO ANSWERS, February 16, 2011 RON R ANDERSON, SHERIFF Ryan Burgett, Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor OFF t „ I . -:RIFF FILED-OFFICE F THE PROT oun, 2011 SEP -2 PM 2: 36 (CUMBERLAND COUNT`' PENNSYLVANIA-, Discover Bank vs. Rosalind G. Graeff Case Number 2010-6114 SHERIFF'S RETURN OF SERVICE 02/11/2011 12:50 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on February 11, 2011 at 1247 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant.-to wit: Rosalind G. Graeff, in the hands, possession, or control of the within named garnishee, Susquehanna Valley Federal Credit Union, 3850 Hartzdale Drive, Camp Hill, Cumberland County, Pennsylvania 17011, by handing to Patricia Sheffer, Receptionist, 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 16, 2011 to Rosalind G. Graeff at 1770 Peyton Randolph Court, New Cumberland, PA 17070. 09/01/2011 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: $95.31 SO ANSWERS, w September 01, 2011 RON R ANDERSON, SHERIFF c) County5uta Sheriff Tel eo.=.oft ' ( "o-