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Home My WebLink About11-1042 FILED-OFFICE OF THE PROTHOINO TAF ', 2GI I JAN 31 AM 11- c-, ? CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff VS. EDWARD P PHILLIPS Defendant No: f /_ WO, [) /'t/l1 ) COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 08806388 C J Pit SJS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff VS. Civil Action No EDWARD P PHILLIPS 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, CHASE BANK USA, N.A. is a corporation with offices at 200 WHITE CLAY CENTER DR, NEWARK, DE 19711. 2. Defendant is an adult individual(s) residing at the address listed below: EDWARD P PHILLIPS 116 SHIRLEY LN BOILING SPRGS, PA 17007 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 4640182011768474. 4. Defendant made use of said credit card and has currently a balance due of $11335.15. A true and correct copy of Plaintiff's Statement of Account is attached hereto, marked as Exhibit "1" and made a part hereof. 5. Defendant is in default by having not made monthly payments to Plaintiff thereby rendering the entire balance immediately due and payable. 6. Plaintiff avers that the Agreement between the parties provides that Defendant will pay Plaintiff's attorneys' fees. 7. Plaintiff avers that such attorneys' fees will amount to $300.00. 8. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, and accrued interest or any part thereof to Plaintiff. WHEREFORE, Plaintiff prays for judgment against Defendant, EDWARD P PHILLIPS individually, in the amount of $11335.15 with continuing interest thereon at the statutory rate of 6% per annum from November 26, 2010, plus attorneys' fees of $300.00 and costs. WELTMAN, WEINBERG & REIS, CO., L.P.A. James C. Warmbrodt, 24 436 Seventh Avenue, u to 1400 Pittsburgh, PA 15219 (412) 434-7955 Fax (412) 338-7130 WWR#:8806388 THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. Payment Due Date New Balance Past Due Amount Minimum Payment D4/04110 511,335.15 51,939.00 $2,375.DD Account number: 4640 18201176 8474 1 Make your check payable to: Chase Card Services. Please wale amount enclosed. New adtlress or a-mall? Pnnl on back. CHASE 0 46401820117684740023750001133515000000000000001 9912B SEX Z 21010C EDWARD P PHILLIPS 116 SHIRLEY LN BOILING SPRGS PA 17007.9593 IrrJILrJIIrrrlLrrLr,llr1.rrl,Irlrlrrr,IL.rrll.ll,.r.l,ll Irrrlllrlrrlrrlrirrlrrllrrrlrlrrrrllrlrirrrllrrlrlrrrilrrllrrl CAROMEMBER SERVICE PO BOX 15153 WILMINGTON DE 19886-5153 1:S000460261: LEI 220 L L 7684 71L. Wo amazon.con Q Manage your account online: Additional contact information www.Chase.com!amazon conveniently located on reverse side ACCOUNTSUMMARY Account Number: 464018201176 8474 Previous Balance S11,012.06 Fees Charged +539.00 Interest Charged +5284.09 New Balance S11,335.15 Opening/Closing Dale 07108110-08/07/10 Total Credit Line 59,600 Available Credit so Cash Access Line S1,920 Available for Cash So PAYMENT INFORMATION New Balance S11,335.15 Payment Due Date 09104110 Minimum Payment Due 52,375.00 Late Payment Warning: If we do not receive your minimum payment by the dale listed above, you may have to pay up to a S39.00 late fee and your APRs will be subject to increase to a maximum Penally APR of 29.99%. Minimum Payment Warning: If you make only the minimum payment each period, you will pay more In interest and it will take you longer to pay off your balance. For example: If you make no You will pay off the And you will end up additional charges balance shown on paying an estimated using this card and this statement in total of... each month you about... pay... Only the minimum 35 years S39,140 payment S483 3 years 517,403 (Savings=S21,737) If you would like Information about credit counseling services, call 1-866-797-2885. It's not too late to resolve the outstanding balance on your credit card account. We have a variety of payment options that may be right for you. Cali 1-888-792-7547 (collect 1-302-594-8200) today. Important Message: You Are Overlimit! Your statement balance exceeds your credit line. You should make a payment that includes the overlimii amount to bring the balance under your credit fine. This account is closed and not available for new transactions. If there is a balance please continue to make payments by the due date. AMAZON.COM POINTS SUMMARY Previous Points Balance 0 Choose from cash, travel. Amazon gift Points earned on all other purchases 0 certificates. and more! To redeem your points Points forfeited this period 5,288 visit www.chase.com/amazon or call Remaining points balance 0 1-800-603-2265. Your card allows you to earn points faster than ever! Earn 3 points for every eligible dollar spent at Amazon.corn. Earn 2 Winls for every eligible dollar spent on gas, dining, drugstore, and office supply purchases. And earn 1 point for all other purchases! Choose rewards for as few as 2,500 points! For complete program details, please refer to your Rewards Rules and Regulations. ACCOUNT ACTIVITY Date of Transaction Merchant Name or Transaction Description S Amount FEES GHARGEp 06104 LATE FEE 39 OG TOTAL FEES FOR THIS PERIOD 539 OG INTEREST CHARGED C8106 PURCHASE INTEREST CHARGE 278.76 08106 BALANCE TRANSFER INTEREST CHARGE 5.33 $8063$$ TOTAL INTEREST FOR THIS PERIOD 5284.09 This Statement is a Facsimile - Not an original EXHIBIT 0000001 PI533335 C 2 000 N Z 07 10100;07 Page 1 aQ 06236 t.1A NIA 99120 21a10000020009912001 X 0441 4 °anmx4nerh?.??+!x, nc-, -.'.r?rrs-_+.a vw. , Address Change Request Please provide information below only if the address information on front is incorrect. 8806388 Street Address: _„__.____ City: Slate: Zip: Home Phone: ___ ___ Work Phone: -?_- E-mail Address: ________-__.____- To service and manage any of your account(s), we. our representatives, JPMorgan Chase representatives, and/or affiliates, may contact you at any telephone number you provide to us. Please refer to your Cardmember Agreement for additional details about the use of your personal information L and/or visit our website shown below to provide us with additional contact information. To contact us regarding your account: By Telephone: ?j ® In U.S. 1-888.247-4080 ? V"V `J Espanol 1-888"446-5308 Send Inquiries to: Mail Payments to: Visit Our Webs item TOO 1-800-955-8060 Pay oy phonel-800.436-7958 P.O. Box 15298 P.O. Box 15159 www.rhase.conUamazlur Outside U.S. call culled Wilmington, DE 19850.5298 Wilmington, DE 19886.5153 1.302-594-8200 Information About Your Account Cns ihng at Paymads: You may make psyuum9 by may c1 the options (kill Wis., The amount of your payment arm of a atkast your m-rimam payment one, payable in U.S. doi and drawn or uayeble through a U.S. more dal imitti.ked a J. U.S. branch on a tomlgr hams Irm:cmon. You may nnar polymers by leg.. L.S. man. Strait your poynhnt to Ili Psyimnas add ,a shown an The statement Your payments by mail most comply w N toe msbuctions an Has stUauaYd. Do :el send Ni Write Volt Account number al Vdi check or money ardor. Payments mutt M atcompaloed by tilt paynenf canpoR In the envelope provtoea who our address visible though Ire envelope rvtapw; 101 envdoa cannot cdnlam made It. one cuti ar coaow and them can be Ira stale. Caper c ips, tel: or corrgpondow induced c Ito Your payment If your payment is in accordance with Oar ppynlw'nst .flons and is made availably to us an anyday, ttry 5Witold. glhmtdour PdymeIba6urnscm -a will volt t tee payment to your Account as of that day. If your paymam It in accordance with ore payment solutions, bill Is made Zwick- to us ale! 5.00 P.M. load bum at IM Payments address on this staement. we will Credit 0 to your Account as 01 Nc Next Islander day. Yea may make payments electrommiyO muga ocr Iwbsfashown o i this sbhrnenl If svu (emus your CumpNlal ICgred an uu wMude try 5 am. kakrn line, wd will -11 your daymm' as al that Oay If w? ratasve your hoUrst Alter 5 am. Eastern Time we will credit your payment as of Ito flux: culerdar day. If you suedy a tutee dna,a your Mg= W. wall credit year payment as of that day. For all ulhet myrnecla a fur any JayPlali type abuse fur which yea do Pat follow our payment iataclide s, free-drq of your Payments may ere delayed for up c 5 days. Account Idarmalion RsperNO to CmdR eunaur, We trey report information about •;ocr Amount to Credit bureaus. Late peyawnn. mMtd payments or ether ditauits on your Accaant may ad differential in your credit report It you think vac him reported iatCUmig infCfmdtdn •d a c:edit Ontario, you may rime to us m the Inpulnes address xluuwn an ids surat nt. To smile and bureaus Any of YowAccoud(q: We, our representatives JPMorgan Chase representatives, ahd)a alltala, may contact you al any telepllaw rencer yT. provide to as. Please Warta your CardmemarAgreement for addiiwal details about [lie use of Yew persawl mlamabol. Malta Abed Elecimic Check Conclusion: When you pay by chock, you authodte as aMor n use o'olmadol tram Vast check to lake: a one-time Cectmn'c fund Inciter it" your account onto process the peymarl as a check Vansachor, Wren we use IWarilital load your check 10 nuke at erd:burlm fund lwII51N, funds may be rvbadrawn from. your account as soon as the same day wo Hain your payment, ano Vito war not beano your coeds bade Imm your financial Irstifillon. Call the Customer Sonia member m Nis s:ahmen[ n you Yave quasrors flboul decnroiic check coltdissn or do not wind your aymads cohKohl electmu cally. Contingent Payments: Any payment chock or other ram of DAYnatn that you send us for loss than tta lull bean" duo dial is iii•pad in tuft or curtalaa a almilan notation, it :hat you otherwise tender in fall satidacticn of a disouled amount, must be sent to Card SWIc43, P.O. Box 15049, WOMilptlm, CE 19950.5049. We resolve all out again; moo-ding theca parchments Ig.g.. It it is doa-mmod Nora Is an va•d dispute or f any such 0hedk a received at any other address, we may accept :ho check one you will still owe any mnalnlap balance). We way slow to occom zny such paylrrt by Ithrmng t to you, ,at gs0irg it a Ikslm inn it. All o -er payments mot you "take should he sent •a his ;egnAar Payment address Shawn on '.Ilia sli tat. Actual R...N ai Malin: U your Account Agkeco ell has an trend momboNrip too aocmr s,most cc ;)e for issuance or availanhty al your account. L' will he bided ach year or in mart fly gin quarle:ly Ir sWtmanl6. True lee sIWO' charge are awed Winner or no! you use your Acccul aid you agree to pay Own when billed. The JIl'rld 'era and outgo am leaf-refundabid uwlas you nodry us (tat you rv:sh in CID. your aucaunl wilbin 30:9ys a era plying cyde!•wdlcheva is loos) atlas as pn swi, tiro saement on which the umual lea or charge is balled and at the same Time. you pay vuur outstanding balance in hdl. If you der fill, far a charge b:lied mom -flan If modally auto u a mnah y service charge. You win not owe ins Last o,tend crerge: Int,"ver, prior billed Idsilgee are nan-relmldalre aid must tat paid as part of Paying VDCr outstanding tali In h I. Your aYnento the Armed fee err charge does wt affect our ngiln to close your Account and to limit your right to male transaclors on your Account. If vour Account :s closed by you or us. •.ve vrill commu t to impose the :rrllud fee a:ufu: lilatge wtil you pay YOM OASW IWO 7ulina m 1011 and lalrnut! Your ACaunf rClalkneh•p. Calculation al Eaton subject to rnfenst Rah: It hgJN your air atlln interest charges for each OI'ling cyde when a day pe'`rldic crisis) spouse, We As the daily balance nmNUd (ahdudiug Curnem 110h tiers), To figure your peliudic interest charges'ar MIN ailing cycle weer a montry perkek ratolg) AVIMS, Ave .0 INC a,. age cads balance melded (.,clod:ng cunenl traRSaclums). Por an exdanator or Carer method o questions abdo a padialcr b romd, wings eatcrbroon on your satallanl. please ad"at :he [fill Iran customer serum grow. Number listed above. 'No eaku ate ponaele nmest :huger. [sing tie appntabld padodtc rotes shown un Ibis 591enlenl, secretly to euch Ieatae (e.y Oelulq denier coca and wall advance Checks ("check Irarlacgen"), purchases, balance (:enders. cash amounums, aadotoml balances or overJ2h advances), then glculatka may ccmbirs diferem a:egurks wild the same ariodic rates. Variable rates wil vary with the market based on the Prime Rate (.or such maOxdetcdbed its your Aceuum ligreamem; Them is a minim am interest chadpe eS 150 for such amount Catchall rl your Account Agnsulet) ei any balling cyck in which you owe ally pullida; In:e•etl thugae, and a mmUd110n'It hx Mail Oaente "angler Cash adw9ntA, nr chuck Rid"0en, in Ice simul te staled in your Account Agfeenmal, as it may be amended. Thera is a foreign trensartkn In of 3% of lilt U.S. do far amount dl, any Interior Iransadwn (a such around desuvoted in your Account Agreerrart). Now to Avdd Paying (merest an Puncluses: We begin assessing periodic mitemst charges an a transaction, fee, or Interest charge Imm tae date It is edged to your daily Isaiah" cold your Account is Will m lull, as desCdOed m your Account Agreement. Yost due data •dk be a Innhaum of 21 days Idlni n9 fM dose of each Wibng cycle. You can avoid periodic Inteert thNgas an new XtChaNS when trey ate Ore. at led to a state Pont as dasunbed blow. feu: One On hid apply IN belong, bander, cash adwI1C06 or drundraft advanced. If you reeds a cannot monthly atatemont that incttda new purehMs and make A Payment mat eve (ecd" Cy Ito 09% and Ilene the vinimum oayment is Can for that shipments. I" wig not Chum poodk interest on any contact of than rtw di ensan tint we adDeMe such pay-mat to. an long as 1) Your current statement also snOW4 that we received wrient of fine and rig lattice lot your previous moms defemem by the safe also On As M9lrmarn Paybnarl wax due OR 2) that Ne ending batunq for year arayrous month a sbmemenl was aano. ll you have a baanae other licks a pachm •a`anah and tat bafenbe came a higher periodic interest rile, you may not be able to aided periodic must tat charges on new purehans if you do di pay your bland, in full each Mi because we generally albcale Payments amt as Mad balance VI ire refusal, periodic Infora: rate. Wkal To 00 II You lhla To Red A Mistake On Yaa SlaMm.1 :I you Ilene them is in error on your statement, write to us on a separate sheel at Customer Service, P.O. Box 15299 Wifm raplon, DE 191150.5299: In your bitter, give us rile folfonng imoncdion: • Account hatamatioR: Yea tome and Account am, . Der. • Dollar amount: I To dollar larmil of the suspected ono,. • DelantMgn Of Pro*M: If you think Item is an error on your bill, describe what you bef we is wrong and Why you bolbve it is a mistake. You most contact us vnlhto 60 days after the ano• appeared on your lacteal YIN must adAly ax at any po tonal frodes In wrdln9. Yost (nay call an, ad It Volt an we a•a not "guin l :C invesigdte any potential gnats and ya may have to pay the amount In I...too. While w: Im`cstpah whether or not there rue ban an error, the fallowing arc true: • We CANNOT TV incorrect the armbn9 a quntmn, err rewhyal asdednquenl on lid w-ni. • Tte charge IN oust ah may romatn did your stdement, and inn nay cards to Cnage you :nlaa: 011001 amounC But If we dt rrmme that rw made a mistake, you will Rol have to pay the amount in question or ano Inaresl err ul9e• lees mleled lu flat anvad. • While you do rot have to pay Me amount M question, you are rilsoonsidic tali Intl Miramar of your baladi • We can aptly my unpaid amount against Year CUI iWit Your Right 11 You An 0inglsfled Wlm Your Credit Card Purchases II you are dissatisfied with Ire goods or services II you have purchased with you credit and, and you nave mad in good gild to correct the problem wan Ire merchant, you may have the right not to Coy thetanning atount out oa ine purchase, To oil this ri all cf the InIdBVlrg M69 On truer 1. The purchase must have been trade in your hi sure Us within IN noes o' your ourrert mailing address, and :he purchase pines .musl'ave bean alone than Sao. ltlow Mulder d owes we Oectarmy t your mi chaae was Intend at an aevew9emenr we mulled to you, or if we awr the company Imm salu you it., guullx a, sine a.) 2, vas must rave data your eNJlt cam fa the alrchaae. Purchases made,. with cash advances Item an ATM or with a clfedk first accesses your credit a'd Acwum do not quakty, 3. you must not yet have fully said tonne precision. II an of Ire crow shown am and, and you ate sale dissarslled min tire purchase. con= us to wr ig at Customer Soria, P.O. Box 15299 Wilmington. OE 1DB50-5299: Write wo IwP.digale. the Sam rata apply m the mspufed amount a9 dtaCltuagd above. Alter we harbor our investigation. Ave will tell you our oee9mn. N that point, d we thkek you ova an amount and you do dal pay vie may report you ai dddmuwt. MA6P9PO10 Statement Dale: M08110 - 06/07/10 Accoun( Number. ' 640 1 B20 1176 8471 Page 2 of 2 2010 Totals Year-to-Date Total fees charged in 2010 5195.00 Total interest charged in 2010 51.795.33 Year-to-date totals reflect all charges minus any refunds applied to your account on or after January 31, 2010. INTEREST CHARGES Your Annual Percentage Rate (APR) is the annual interest rate on your account. Annual Balance Accrued Balance Percentage Rate (APR) Subject To Interest Interest Type 31 Days In Cycle Interest Rate Charges Charges Purchases 29.99% (v) 510,944.67 S278.76 50.00 Cash Advances 29.991 (v) S0.00 50.00 50.00 Balance transfer 29.99% (v) S209.22 S5.33 50,00 (v) = Variable Rate Please see Information About Your Account section for the Calculation of Balance Subject to Interest Rate, Annual Renewal Notice How to Avoid Interest on Purchases, and other important information, as applicable. 8806388 This Statement is a Facsimile - Not an original X 0000001 F1533335 C 2 000 N 2 07 10108 07 Page 2 of 2 06236 AM MA 99128 21910000020009912aD2 VERIFICATION The undersigned is an Officer of Chase Bankcard Services, Inc., which is a subsidiary and agent of the Plaintiff that maintains the records and services the credit card accounts owned by the Plaintiff. The undersigned is authorized to make this verification for and on behalf of the Plaintiff and is familiar with Plaintiff's account in this matter. Based upon my review of the Plaintiff s books and records of Defendant's account(s), I have personal knowledge of the facts set forth in the attached pleading. Records such as these are kept in the regular course of the Plaintiffs business and it is the regular course of Plaintiff s business to maintain these records. These records and the entries thereon are made at or near the occurrence in question by, or from information transmitted by, a person with knowledge of the account. This verification is made subject to the penalties of 18 Pa.C„S.A. §4904 relating to unsworn falsification to authorities. WWR#8806388 Client Account #4640182011768474 Name EDWARD P PHILLIPS SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 2 FILED-OFFICE 11 FEB -9 AM 9: co I ENNS Y L M fl I A Jody S Smith Chief Deputy Richard W Stewart Solicitor Chase Bank USA, N.A. Case Number vs. Edward P. Phillips 2011-1042 SHERIFF'S RETURN OF SERVICE 02/01/2011 04:35 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on February 1, 2011 at 1635 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Edward P. Phillips, by making known unto himself personally, at 116 Shirley Lane, Boiling Springs, Cumberland County, Pennsylvania 17007 its contents and at the same time handing to him personally the said true and correct copy of the same. A-A RO ERT 811TNER, DEPUTY SHERIFF COST: $33.40 February 03, 2011 SO ANSWERS, RON ? R ANDERSON, SHERIFF February 11, 2011 James C. Warmbrodt, 42524 Court of Common Pleas Weltman, Weinberg & Reis Co., L.P.A. Cumberland County, Pennsylvania 436 Seventh Avenue, Suite 1400 1 Courthouse Square Pittsburgh, PA 15219 Carlisle, PA 17013 Attorney for Plaintiff: CITIBANK (SOUTH DAKOTA), N.A. [= `+ t Re: Chase Bank USA, N.A. rnco 200 White Clay Center Drive z'? w _ Newark, DE 19711 „ a r- V. No. 11-1042 Civil >? = ?'?a 3;4= co Edward P. Phillips ? cn 116 Shirley Lane ?` _ Boiling Springs, PA 17007 To Whom It May Concern: This is in response to the above-referenced claim which was served upon my premises on February 3, 2011. The aforementioned claim indicated a measure of monetary debt that I owe to the claimant which I am currently in default on. I do not contest that the debt cited in the above-referenced claim exists and I do not contest that I am responsible for some measure of it. However, I do contest that amount claimed therein. Furthermore, the majority of the debt so cited was accumulated during a period of hardship for me, which included the death of my father, the partial support of my newly-widowed mother and a temporary martial separation which required me to assume the majority of household expenses which had hitherto be shared between myself and my spouse, including childcare expenses. While things have improved to the point where my widowed mother does not require my support and I have reconciled with my spouse, a period of financial recovery is necessarily required before I can make payment on the portion of the debt I owe. My creditor, Chase, has not afforded me very much time in this regard, and I would like to point out that the amount of time I have been in default is little more than one (1) calendar year as of my receipt of the above-referenced complaint, while the course of my hardships transpired over the course of two (2) to three (3) years. While my intent is to repay the bona fide amount of the debt I owe, I have not yet gathered sufficient resources to make such payment and request more time to allow my financial recovery to become complete. Furthermore, I do contest the amount of debt cited in the aforementioned claim made against me. I respectfully request the patience of both the Claimant and the Court in this matter until I have recovered sufficiently so as to make satisfactory payment on my outstanding debt. Sincerely, Edward P. Phillips WELTMAN, WEINBERG & REIS CO., L.P.A. BY: William T. Molczan I.D. No. 47437 436 Seventh Avenue 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 Fax: (412) 338-7130 File # 8806388 CHASE BANK USA, N.A. VS. EDWARD P PHILLIPS L U?4BERLAP???COlA jj' ?ENNSY Attorney for Plaintiff(s) Cumberland County Court of Common Pleas No.: 11-1042 CIVIL PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss the above matter without prejudice . WELTMAN, WEINBERG & REIS CO., L.P.A. By William T. Molczan, Esqu' Attorney for Plaintiff 111111 IN 111111111110 111111101111111111111111111111111111111111