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HomeMy WebLinkAbout11-2902b pp F? C U M, B Ef lAj' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff VS. JOHN K RIORDAN Defendant No: // - ; 111 vi 'l 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 08863986 C J Pit KMJ Vet/ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff vs. Civil Action No J'OHN K RIORDAN Defendant COMPLAINT AND NOTICE TO DEFEND You have been sued claims set forth in the twenty (20) days after t a written appearance per with the court your defe against you. You are wa proceed without you and court without further no for any other claim or r money or property or oth court. If you wish to defend against the llowing pages, you must take action within s complaint and notice are served, by entering nally or by an attorney and filing in writing es or objections to the claims set forth ed that if you fail to do so the case may judgment may be entered against you by the ce for any money claimed in the complaint or ief requested by the plaintiff. You may lose rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT A FORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT W ERE 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. LA YER REFERRAL SERVICE RL?ND COUNTY BAR ASSOCIATION 321SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff, CHASE BAND USA, N.A. is a corporation with offices at 200 WHITE CLAY CENTER DR NEWARK , DE 19711 2. Defendant , is adult individual(s) residing at the address listed below: JOHN K RIORDAN 15 BRADFORD CT MECHANICSBURG, PA 17055 3. Defendant applied forland received a credit card issued by Plaintiff bearing the account number 4266841078054283 4. Defendant made use ofsaid credit card and has a current balance due of $9696.24 . i 5. Defendant is in defa4t by having not made monthly payments to Plaintiff thereby renderi?g 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 efused to pay the principal balance, and accrued interest or any art thereof to Plaintiff. Wherefore, the Plaintiff prays for judgment against Defendant , JOHN K RIORDAN , individually , the amount of $9696.24 wi- h continuing interest thereon at the statutory rate of 6.000. per annum from December 20, 2010 , pluslattorneys fees of $300.00 and costs. ames 436 S6v 08863986 C J Pit KMJ Pitt5su (4121 FAX- 4 This law firm is a debt c llector atte p in our client and any information obtaine it . Warmbro=,42524 WEINBERG & REIS CO., L.P.A. nth Avenue, Suite 1400 gh, PA 15219 34-7955 2-338-7130 to collect this debt for be used for that purpose. Payment Due Date New Balance Past Due Amount' Minimum Payment ' 10101/10 S9.971.24 F 5822.00 $1,096.00 Account number: 4266 8410 7805 4283 . Make your heck payable It Chase Card Se,,=.a ices. Please write mount enclosed. New addrel ore-mad? Pnnt on back. 42668410780542830010960000997124000000000000004 43050 BEX Z 24710 D JOHN K RIORDAN 15 BRADFORD CT MECHANICSBURG PA 17055-5792 ..rill,rrJrlrJJrrI,L11rr1Llrrrrlrl,rrl?JJr1rIL Irrrlllrlrrl,ctrl,rlrrllrrllrlrrrrllrlrlrrrllrrlrlrrrllrrllrrl CARDMEMBER SERVICE PO BOX 15153 WILMINGTON DE 19886-5153 1:5000160281: 20 Ei10 780 5 4 28 3 511- CHASE O 1q_ your account online: Additional contact information ?se.comrcreditcards conveniently located on reverse side Account Number: 4266 8410 7805 4283 Previous Balance 59,866.91 Payment, Credits -S274.OQ Purchases +$274.0 Interest Charged $104.3 New Balance S9 971 2 Opening/Closing Date 08/05/10 - 09i0411 Total Credit Line S12,OI: Available Credit 52,02 Cash Access Line S2,4C Available for Cash S PAYMENT INFORMATION 7771 New Balance 59.971.24 Payment Due Date 10/01110 Minimum Payment Due 51,096.00 Late Payment Warning: If we do not receive your minimum payment by the dale listed above, your APR's will be subject to increase to a maximum Penally APR of 29.99°/x. 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 529,151 payment 5331 3 years 511,933 (Savings=517,218) If you would like information about credit counseling services, call 1-666-797-2665. Your account is on a payment program. The Minimum Payment Warning disclosures may not match your payment program terms. The charge privileges on your credit card account have bee revoked. You no longer have the ability to use your credit card account for purchases. We can help you gel back on track, call 1-800-955-8030 (collect 1-302-594-8200) today. This account is closed and not available for new transaction. If there is a balance please continue to make payments by the due date. IREWARDS SUMMARY Previous Points Balance 0 Thank you for using the credit card that earns Points Earned On Purchases 0 rewards that can be used for your choice of gift Points Expired This Period 0 cards, cash or statement credits- Remember, Current Points Total 0 you can earn points by using your Free Cash credit card for your everyday purchases like gas and grocery purchases. Your Free Cash credit card earns 1 point for every eligible $ you spend on purchases. Earn additional points - as much as 10 points per $1 shopping online through www.chase.oom/rew rdsplus. Add authorized users, and sign up to have your monthly bills charged to your card. Why not get points for all those purch ses loo? Redeem your points anytime, or just check out new offers at www.chase.com/rewards. Date of Transaction Merchant Nam or Transaction Description 5 Amami PAYMENT AND OTHER CREDITS _ 08/31 Payment - Thank You '7100 PURCHASES 07/31 Ratllmed Payment 2/4 00 INTE EST CHARGED - 09/03 PURCHASE INTEREST CHARGE 71 47 886398609/03 CASH ADVANCE INTEREST CHARGE 32.86 TOTAL INTEREST FORT S PERIOD 5104 33 EXHIBIT 1 This Statement is a Focsimile - Not an original 'X100001 FIS33338 77 000 N Z 04 10r09.T Page 1 oft 05606 MA NA 43050 24610000070004305001 0371 F 8863986 Address Change Request Please provide information below only if the address information on front is incorrect. Street Address: City State. Home Phone: E-mail Address: Zip: Work Phone: To service and manage any of your accou t(s), we. our representatives. JPMorgan Chase representatives, and/or affiliates, may con act 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 andior visit our websile shown below to provide us with additional contact information. To contact us regarding your account: By Telephone: © ' ??II in U.S. 1-800-945-2000 V" ?I Espanol 1-888-946-3308 TDD 1-800-955-8060 Send Inquiries to: Mall Paymanta to: Visit Our WabsRe: Pay oy phonel-800-936-7958 P.O. Box 1529 P.O. Box 15153 www.chase.com/clecitcards Outside U.S. call collect Wilmington, D 19850-5298 Wi mington, DE 19886-5153 1-302-594-8200 Istemmlthn About Year AUnat cash advance checks ('died, transaction"; , purerasU, balance Nansfirs, cash Cndilin d P ab: ycu m a wHa ay :make paymen, by any at the pp liens advances, xomotronal balaaes or o"dmft advances). `rose atlculaboes may sled below The amount of your paymern sra,I A at Net•murm,nimum payment combine tlipemm calliodes will the same periodic rates. Variable false will vary opayable in US. dollars and drawn or payable threegh a U.S. financial ins irl with the market based on the Prime Rate Or such ireox described in your Accaum or lie US branch al a mareIr timr vial Instmnim . Agreement;. Them isa minimum interest charge afS1 50 (or such argil dUCnbed . in your Austrian Agreement) in wry briny cycle In which YOU owe rrr periodic You may vlake payments by regu es U.S. Ml Send you, payrsnt to it Paym mi, iral charges, i d a traneacthan W fir owit adance monster, cash adwi it edemas shown m 'his statement. Your payments by mad must con ty w m the check formation, in the amounts staled in your Account Ag,mmrd, as a may be 11151. buns on this sla;enrhaA Ca Ist send :ash. Write yoar Accupn number on mended. Thera is a foreign I,ansmtlon fee d 3% of the If. S. do tar antrum m any vac check or money Order. Payments must be acmmpaded by me pay- ant coupon foreign formulation (of such amount eewroed in vouf Account Atimemerl). In the 9nve,cm terwaletl with our actions kernels Rea ll BM erwtlops real Inc Hew to Avoid Paynq Interest an comforts We begin aSFe,51n9 periodic 101e195t ioneie cannot Qon tape m currWan ark, esoandenre more ansupromme infiartxsed uroup y..aid . pay ay, s rules. VaaY c tap wa h d your , rt. can N be n° charges on a tmnsactin,lee. or interest charge from lie date N Is added to your dally your P. payment is in accordance wth our peymem Istructions antl Is made err been ce ual l our Area l is paid In full, as described in your Account Agreement . i able to ue en any day b.00 p a our Slater s lal h your due data will be a minimum of 21 days Idlowing the dace u! eaGn bluing cycle. ;Cut we .111 A day If yOyo com Vermont to o your your x paayment ym , sol o : of that t day N is in u as re t , You can avod prig to Interest charges an new ourchaxs when they late Nm: Of led - odance ' Pay-": ns, but en awo to ate! S Oil ymem ,,it om is : p to a statement as described below but this dues not apply to OalarW tra'hsters', . local ante , ddress 00 role atamevxa. ww w won hit creda r it e P address an to your A cash advances or O"drahadvances. Nyou receha a cummt morally stalmormthat our as of ext calendar day. :he next includes new purchases and ma"a paymentlndwe reed" try lbe date and time the ' Minimum -a man s due for that staemem, wt will rat charge Y periodic i YDJ or or make paymaniF electronically mmagi QbrYYebaA05IlOWll on ill Iwo a FGlement. any port in of thieve new aadhabeei'la Ym Alta;pee Such payment to. Fin long as 1) l) Ir we Ncewe yen completed regxsl an a.r consae by 5 o.m. Eastern I me, we will Ycu- currant sleWnent also snows Nat W recall payment of the and ing Anne erect your oaymen: as of teal day it xw rote:" error 'squeal after 5 m. Pastern for yoh.riffevious morons $Utemem by the allowed time its ASnmmm Payrrerf was Time, we wi l crndh ywf payment. Dt the nett calendar day. It you s itya future due OR 2; that lute eating balance fur your srevious Tell allotment was are. If date ..n your Mail we wall credit your payment as of that day you have a be wee Other tlsn a purchase aaralce and that dance cartles a higher bur all of:ler pay nts or for al any rYmsnalypeabave for will you don periodic interest ralt. you may not be able to avoid periodic iistd charges on new t 1d0w act h if d payment inalNCtione, area line Of Yaur P3VMK4& maybe delayed for up purc ases you o not pay your balance in lull each mail because we generally a days. allocate Payments amt td per balance with the ^,gra l Import mentia rate. Mason Ietarmeaern ROPOFUd to CMU awraa: We may report affai ation about What To De If Y. Think Yu Find A MIe1Wr of Yon su*MrA ear Attach-, to credit bureaus. Late ,roymm*s, missed Payments or a. defaults YOU, Accovn may pn it"reled in your credo report It you think eve h reported it you Ihtn, there is an error an your Statement, are to us 01 a separate sheet at i rudcamte in•armahon roe cradih human, you may erole no user the Ire i des address Customer 5eNca.P.O. Box 15299 Whaingam, 3E 19850.5299: shown on this statmert !n YOLr letter. give us the following int nandion. To Semler and Mump A" ON Your At ..a ltst:gle,currepresentahm JPMorgan Chase aDres entatives, acrd" affiIa , may coned you a any ;aleph e rummer ' Account Manhattan: Your rams and Account number, you. povde tots. Please refer to your Cardmemoer Afromment foradi anal details •Ondar amour:thedollar Amountofthe ancestor! r- abuul the use of yon Plavental IifamaUOr. Made* About Electronic Chick Ceewrdoh: When you pay by clack, y • Baser fallen Of Problem: It yoc think more es an error or. your bile, describe authorize what who you beLeve is wrong and wiry you believe a IS a mistake. u us r.iber v use se in'cr, intomadan from yaer check to make a on,-Noe e? hirel mmc luntl ,mrsfer 'mm Your account oe to process -,he psymert as a check trail ran. Wean You must coma uswthin 60 days after the emp'appeartt oh your stalcment we use mlurmanun 110m your check to make so, e1H:berpC rend transfer ithd f be funds may You Must notify es of airy potertial Priam In wrang. You may cal', net an it you In w irei rom youraaount as coon as the some day wet mwi" a d you will not receive ypur c:mdk Made from your foarciai Nstitut' , payment, we We an[ recall :d ievesugate any paemia errors and yet may ha" to pay the n ca l the Cus'amer Serrias number pn Nis V teM M N you ha" questions al . amount In quest'an. eleciroric check col ectron err do not wren ear payments cu8eeted nlecfron caty where we Iaventigeh whether or not them rats been m emor toe following a,e true. COn8111oaai PsYmMIC Any paymom check or UNef fora cf VaynomN you send •Warannnttrymearthi pmalaN forstlpp, ormtrfurl as Mallagmmon ulfir less than its lug be mat due balis Wield "Paid in lull" or cortir s a soniur Ilsl amaol. notation, err, :hat you adsrvdse Murder in td saisfacl of a diseu amount roust be sent to Card Services, P0. Box 15049, Wilmington, CE 198- 5009. We ' Tna charge In Question =Y remain ar your slaemeMI and we cosy cdrhnus reseve all our rights mga'dinq these payments ie.g., if It Is deaVminea mare is no to carge yoxi rterear an trot amount. Out, we determine that vie made a va d dispute or I any such chock s received at arty other address, we y moral mistake, you will not have to pay the amount in ruk elion or any Interest Or :he check ann You will still awe any remaining balance). Wet may rtu to maePt plhe' lees related to that u,rcunl. any sich paymert by certain h to eau, not cashing it or destroying I. All other . While you do mot have to pay the amour n question you are responsfak for payments that you make should be N't'a tbe'equfer Payment addreser , shown on life ren'ammu, olyuut baance 'Ills stalemeal, . Annual Renewal Moller. If year Account Agrkemert has an annum rem • G e ership foe We Caa apply any unpaid amount agemt your reer arl atom ,.Mier cra'ge la isapenra or evailadmy it your account, h with be biked each Year flights If You An DinNiefid 1Wth Too, Credit Card Portions year or in monllly or quarterly Installment. This tit Will charge am e•. d wtel ur m! You use your Acckeun:, aid you agree to on them wish billed. it you are dissaislied with the goods o, savnes that you Nave purchased with y our he "I'laaf / 'ace as charge am non-refuidade unless yet many us era you rest. to close your credit cad,andy V. had a good Faith t0 carmmns mclown On his merchant. account within 30 Jays or one bhnng Cyco 4viniche"r is ass; anal we oweal the you may ha" tire right not to pay the rarrsirlup anourt due on to eactual staa,renl on waken the annual IN or dlarge is In tied and at the same ti. a, you pay TO use this fight 211 0 me following mh.st no tma yoer outstanding baance in full. N Yet, do irks, for a charge bked amm Am thar annually such a, a month 'y service dlarge, yea win net owe the ,1a In I d charge. I. the purchase most have taken Mae is your home state a within 100 mats hubs"6 prior billed charges are non-relun l le and most be paid ns pa o' paying of your arrest mailifd address, and the Durchase price must 'a" been .vOLf outstanding bell In h 1. YOU pays Of tie annuual fee or cis does rim .'norm the, Sil (Naar'. Kahl d N. are rwrxssary If your purchase was effect our rights to dose your Account and to limit your ignl'o make mare ace ors ou eased on an aC"nisement we marled to yet, or two, own the company net ym.r Acmunt. Il YOU, r Account S clause by YCp Or us,'."-ill confirm to prim the sole you lire guWs or ."I- ) annual lee andlu' Marine idiot you pay your OASUrdth2 Alaoce in lull an tamirNle 2 you m t r your Account helndnsh:p, . as ave used your dm9t cad for the purchase. Purchaaw made with cash advances Imo an ATM ar wuh a clock that accesses your credit ..it Correlation at BaMace SubJrd to Merest Rath: If,, tipm. your car o In uri Account do Trot Qualdy. charges for each piling cyder whet a dally pe,edit moats) antlers, we a b l the Ally 3. you thus[ Hat yet ha" fully avid Far ter m"Jusse a ance methud (including current Parcaddrsj. To figure your pe li charges for each bllArg cycle wren a mx ptrty pencom mats) atipllas, , . is densest re Ac the It no Of tre cllterla aba•.rc am me: and you are sill i issahs8ed win me puinsess ave•age early balance mahoc iadudmq current IrarswmhsJ "ar all ex arml:or of con:acl us in writing at Customer Sony ce, P0. Box 15299 Wilrr.rlgtdn. BE sift,: method. cr woofer ns about a Arlieda interest charge cafccla' on your t985a5299 smlemem. please as I US at the tell Nee customer s,fir. prone number li, d above We cakuate pori0dic ntemst charges . usng in appdpbs periodic r Whim Ica Inveainish the saint rules TO the ue amour as oin it as shown aboveAcres' car IinlFe O ' n t t l 11 the smlentent, secaatnty la emh ferwe(t.g., balance ummler. w p t ion, we we wi l l am you ou our Cecsdn u i ves iga i. At tea point. if rocks and wethihk you Oman amountand youdonot pay we. may rWWvouasdellrmUd. MA6792010 _ Statement Date. 08/05110 - 09!04110 Account Number_ 4266 8410 7805 4283 Page 2 of 2 Total fees charged n 2010 v-aVywN S0.00 Total interest charged in 2010 S82755 Year-to-date total reflect all charges minus any refunds applied to your mount on or after January 31. 2010. Your Annual Percentage Rate (APR) is the annual int esl rate on your account- Balance Accrued Balance Percentage Rate (APR) Subject To Interest Interest Type 31 Days in Cycle Interest Rate Charges Charges Purchases 1100% 56.96710 571.02 S0.00 Cash Advances 12.00% S3.224.18 53286 S000 Balance transfer 12.00% 50.00 S0.00 50.00 Please see Information About Your Amount section fort a Calculation of Balance Subject to Interest Rate. Annual Renewal Notice, How to Avoid Interest on Purchases. and other importan information, as applicable. 8863986 This Statement is $ Facsimile - Not an original K 6000001 FIS33338 0 7 000 N Z 04 10i091N Paye2 cf2 05686 MA MA 43050 24610000070004305002 V VERIFICATION The undersigned is an Officer of Chase Bankcard Services, Inc., which is a subsidiary and agent of the Plaintiff that maintain 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 famil ar with Plaintiffs account in this matter. Based upon my review of the Plaintiffs 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 Plaintiffs business to maintain these records, These rec rds 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 m de subject to the penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. -. -0- WWR# 08863986 C J Pit KMJ Client Account # 4266841078054283 Name JOHN K RIORDAN IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYPAW CIVIL DIVISION -47z' r'n co CHASE BANK USA, N.A. = Q o Z? r 7l. Plaintiff No. 11-2902-CIVIL > C-) >? c) C-) C-? vs. ACCEPTANCE OF SERVICE r- ' -- JOHN K RIORDAN Defendant 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#08863986 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff vs. Civil Action No. 11-2902-CIVIL JOHN K RIORDAN Defendant ACCEPTANCE OF SERVICE I, JOHN K RIORDAN, do hereby accept service of the Complaint in Civil Action. DATE: 3 efe dant 1 OTa0; 0 ?! EI r 1€3 PH 3: 43 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff vs. JOHN K RIORDAN Defendant Civil Action No. 11-2902-CIVIL PRAECIPE FOR JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment against Defendant, John K Riordan, in the amount of $9405.77 plus costs, based upon the consent of the parties. CONSENTED TO: WELTMAN, WEINBERG & REIS CO., L.P.A., JOHN K RIORDAN, By: _ Attorney for Plaintiff WWR#08863986 By: i fe dant 1y. o? Qcl obj ?,??C?7(o 3?( ?y?d?S 4 t41 ,n\n? (V117U.1re?. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff vs. Civil Action No. 11-2902-CIVIL JOHN K RIORDAN Defendant S'T'IPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment in favor of Plaintiff and against the Defendant, John K Riordan, above-named, in the amount of $9405.77 pursuant to the Stipulation of the Parties for Payment and for the Entry of Judgment by Consent, as follows: Defendant admits indebtedness to Plaintiff in the amount of $9105.77 with continuing interest thereon at a rate of 6% per annum from March 22, 2011, plus attorneys' fees in the amount of $300.00 and costs. 2. To secure the repayment of said indebtedness, Defendant agrees that Judgment by Consent will be entered in favor of the Plaintiff and against the Defendant, John K Riordan, in the amount of $9105.77 plus continuing interest thereon at the rate of 6% per annum from March 22, 2011, plus attorneys' fees in the amount of $300.00 and costs. 3. Plaintiff agrees not to Execute on its Judgment so long as Defendant causes to be delivered to Plaintiff the following payments in full by 12:00 NOON on the following dates: (a) $275.00 due by April 23, 2011; (b) no less than $275.00 due by the 23rd of each consecutive month thereafter until balance is paid in full. J. 4. All payments are to be made payable to the order of "CHASE BANK USA, N.A." 5. The first payment due under this agreement is to be received at the offices of Weltman, Weinberg & Reis, Co., L.P.A., 436 Seventh Avenue, Suite 1400, Pittsburgh, PA 15219. All future payments are to be mailed to the offices of Weltman, Weinberg & Reis, Co., P.O. Box 5430, Cleveland, OH 44101-0430. 6. In the event of default, each payment received shall be first attributed to costs, interest and then to principal. 7. Time is of the essence of this agreement and should the Defendant fail to have in the hands of Plaintiff or Plaintiff's counsel any payment in full within five (5) calendar days of the stated due date, then Plaintiff shall be immediately free to issue Execution as well as pursue all other remedies, in law or in equity, to collect the full balance of the Judgment entered hereunder plus appropriate additional interest and costs. 8. No act or omission of the Plaintiff, nor of anyone alleged to be acting on its behalf, shall constitute a waiver, estoppel, or any other excuse for non-perfonnance of any duty undertaken by the Defendant in this Stipulation which the parties agree is final and complete. 9. Intending to be legally bound, the parties set their hands and seals this day of 20 1 WELTMAN, WEINBERG & 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 WWR#08863986 B6y- * ant, John K Riordan IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CHASE BANK USA, N.A. Plaintiff VS. JOHN K RIORDAN Defendant John K Riordan 15 Bradford Court Mechanicsburg, Pa Civil Action No. 11-2902-CIVIL NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judgment was entered against you on -/ (xx) Assumpsit Judgment in the amount of $9405.77 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. ()cx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession ( ) Default ( ) Verdict ( ) Arbitration ( ) Award (XX) By Consent Prothonotary 17055 ,-? By: ON Y (O DEPUTY) SHERIFF'S OFFICE OP CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ??z?1?i?? of 4ulrtP?Fr/y?0 } . r? i f 0CT 25 A i f „' 9'° : Lf j L, Li I Chase Bank USA, N.A. vs. John K Riordan Case Number 2011-2902 SHERIFF'S RETURN OF SERVICE 09/14/2011 09:43 AM - Michelle Gutshall, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, 1 W High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Joan Crowl, Teller, 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 September 15, 2011 to John K. Riordan at 1 E Bradford Court, Mechanicsburg, PA 17055. 10/21/2011 Ronny R Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned STAYED, per request from plaintiff's attorney. SHERIFF COST: $87.66 SO ANSWERS, yr, October 21, 2011 RON R ANDERSON, SHERIFF a) jut - ce, 14) 1# 5?? 7G .7 3 'C, Court S t to anea't ! E e osoil, l -- '} w WELTMA: i, WEINBERG & REIS CO., L.P.A. BY: iames C Warmbrodt, Esquire `.seventh A,. imue, Suite 1400 Pittsburgh. PA 15219 P=ions: 412.," 34.7955 Fax: 412.434.795(% Pile # 8863986 CHi%SE BA,,JK 1SA, N.A. vs. JOHN K RIORD ?N and M &T BATIK Ga. nishec(s) Attorney for Plaintiff(s) Cumberland County Court of Common Pleas NO. 11--'9u?.-CIVIL PR.,, ECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO "t HE PkOTI101,a rARY: Kindly .narks. d the abo?,e matter disco. tine: d and en& d as to Garnishee(s), M & T BANK, only. NVELTA iN, WEINBERO & REIS CO., L.P.A. By Sworn to and sus; scribed Before me die . jM day of September, 201 TARY Pi ?_IC COMMONYV Nam? Sol Sheila G. i9?v?n, Net?ty ?Ik ? T4., aMOhwnv coumy My CA1TIfl'IipI0f1 Nov. 15 2014 Mer+WR r+E?msr?vnN ASSOCIATION OF NUrAR1F5 Lot SS'1?y 1Z a UPY3O