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Home My WebLink About11-3504 r „LF')-0Ff is <;,t ?°t CPtiL? r D COUNTY f?F "3 LVA'SIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION 1 * DISCOVER BANK Plaintiff VS. CHRISTOPHER PAU KOHAN Defendant No : 1 ( - 360 0) 01 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 09021713 C A Pit CXC S a. oo?d G.-1111? &-tt511 71sas F-* a57 spa IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No CHRISTOPHER PAU KOHAN 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 ages, 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: CHRISTOPHER PAU KOHAN 6 MANOR DR MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX3799 . 4. Defendant made use of said credit card and has a current balance due of $8043.80 , as of February 03, 2011 . 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 19.490% per annum on the unpaid balance from February 03, 2011 . A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit 111" 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 , CHRISTOPHER PAU KOHAN INDIVIDUALLY , in the amount of $8043.80 with interest at the rate of 19.490 per annum from February 03, 2011 plus attorneys' fees of $125.00 , and costs. ames 436 S Pitts (412) FAX: 09027 This law firm is a debt collector attem our client and any information obtained WEINBERG & REIS CO., L.P.A. th Avenue, Suite 1400 , PA 15219 -7955 338-7130 C A Pit CXC to collect this debt for be used for that purpose. III, Now Balance Minimum Payment Dw Account Number ending in 3799 DISCOVER $0.00 $1,459.00 Enter Amount Enclosed Below Payment Due Data $ February 26, 2011 31 SDSN6A01 0005954 CHRISTOPHER KOHAN 6 MANOR DR MECHANICSBURG PA 17055-6133 Address, email or telephone change# Go to www.Dnc•ver.cem or print change in space above. Go paperless and make your account information more secure with pessword- ected statements only you can access. earn more at discover cornipaperless. PO BOX 6103 111 rrr??rsrrs??rrrr??r?irr? CAROL STREAM IL 60197-6103 611 1,)611n1Illrln6uIIIlnrr1Hli,nBill llrurfill oh$11 000001986833839722782000000000000000145900 Opening Dale: January 7, 2011 Ciosing Data: Jatuc Discover More Card Account Summary Account number ending in 3799 Previous Balance $8,043.80 Payments And Credits 8,043.80 Purchases + 0.00 Balance Transfers + 0.00 Cash Advances + 0.00 Fees Charged + 0.00 Interest Charged + 0.00 Now Balance 0.00 See Interest Charge Calculation section following transactions for detailed APR information Credit Line $9,400.00 Credit thwAvailable- 40-00 Cash Advance Credit Line $4,800.00 Cash Advance Credit Line Available $0.00 31, 2011 aaae 1 of 2 Payment Information New Balance $0.00 Minimum Payment Due $1,459.00 Payment Due Date February 26, 2011 Late Payment Warning; If we do not receive your minimum payment by the date listed above, you may have to pay a We fee of up to $35.00 and your purchase and balance transfer APRs for new transactions may be increased up to the Penalty APR of 24.4976 variable. Manage Your Account "me at www.Docoveir corn • 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 mdew sPaoh rewards • NEW Access your account securely through your mobile phone 3 Easy Ways to Contact US Ca fiwk BOnuie Anniversary 1 Access yaw account securely at www.Discever.e•m ?' 2. Call 1•8004)ISCOVER (1-SM347-2683) October Please have your Discoverecard available Opening Cashback Bonus Balance $ 0,00 3. Write to us at Discover PO Box 30943, New Cashback Bonus This Period + 000 Sok Lake City, UT 841 §0 (Not a payment address( For payments, please send to address on remittance or Cashbock 6arws 5a6nc• s 0.00 Discover, PO Box 6103, Carol Stream, IL 601976103 To team more, 69 in of www.Dhcover.com For TDD (Telecommunications Device for the Deal) assistance, please call 1-800-347.7449. Transactions Trans. Da Dab Payments msd Credits Jon 31 Jan 31 INTERNAL CHARGE-OFF $ .8,043.80 Fees TOTAL FEES FOR THIS PERIOD $ 0.00 rdsrest0witged - - - _ --- -- --- TOTAL ICIM ST fOt11M PERIOD- 2011 Totals Year-to-Date TOTAL FEES CHARGED IN 2011 $ 35.00 TOTAL INTEREST CHARGED IN 2011 118.36 9021713 n? ti lBff I NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION DKENM DISCOVER It pays to CHRISTOPHER KOHAN Account number ending in 3799 page 2 of 2 Interest Charge Calculation Your Annual Percordage Rah (APR) is the annual interest rate on your account. Current Billing Period: 25 days TYPE OF BALANCE Purchases' 07/26/2010 and aher 07/25/2010 and prior Cast Advances ANNUAL PERCENTAGE RATE (AM 19.49% V 17.49% V 23.99% V BALANCE SUBJECT TO INTEREST RATE $0 $0 $0 INTEREST CHARGE $0 $0 $0 V a Variable Rate • Dates apply to not-promotional purchases and to expired promotions with start dates within the specified date range Addhiornal bnportad llskmrotion Important 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 Cordmember Agreement contains all the terms of your Account. Lod or stolen cards. Repo" Immediately! Call 14800-347-2683. YVkat To De N You Thh* You Pied A Mistake On Your iratement l you think there is an error on yaw statement, write to us at: Discover, PO Box 30421, Solo Fake City, UT 841300421. In your labor, give us the following Information: -. AecasM-idwovtwrx-Yew-nomeondoccewt+wmbm.-----------------'- - '--- - ------- -- ----- - ----- . Dollar amount: The dollar amount of the suspected error. Description of Problem: f you think two is an error on your bill, describe what you believe Is wrong and why you believe it is a mistake. You must contact us wlhtn 60 days after the error appeared on your stateruent. You must nobly w of any potential errors in writing. You may call us, but l you do we are not required b investigate any pobnlfal errors and you may have to pay live amount in question. While we Investigate whether or not there has been an error, the fallowing are hue: We cannot try to collect the amount in question, or report you as delinquent on Owl amount. The charge in question may remain on your statement, and we may conlis to charge you interest on dM amount. But, if we determine that we made a mistake, you wit not hove to pay the amount in question or any in 11I of other fees related to two omounb. While you do not have to pay the amount in question, you ore responsible for the remainder of your balance. We can apply any unpaid amount against your credit Omit. Yew tNetsrs 0You Are CbseBdied With Your Crodh Cord Purchases l you are disso0siNd with the goods or services that you have purchased with your credit card, and you have tried in good faith to correct the problem with be aid nk you may have the tight not to pay to remaining amount due on the purchase. To use this right, oll of the followMg must be hue: 1. The purchase must have been made in your home stole or within 100 miles of your current mailing address, and The purchase price must have been mom Own $50. (Note: Nadler of these are necessary l your purchase was based an an advertisement we mated to you or If we own it* company that sold you the goods or services.) 2. You must have used your credit card for the purchase. Purchases mode with cash advances from on ATM or with a check that accesses your credal card account do nor qualify. 3. You must not yet have fully paid for Ode purchase. t all of to criteria above are met and you are shit dissalisffed with the purchase, contact us in writing at: Discover, PO Box 30945, Sob take City, UT 841300945 While we Investigate, the some rules apply to the disputed amount as discussed above. After we Finish our investigation, we will tell you our decision. At that print, If we think you ovre an amount and you do red pay we may report you as delinquent. Payments. Send only your payment and the top portion at this statement in tie enwbpe provided. Do not send Bash. By sending your check as described i above, you authorize us to use information on your check to make an electronic fund transfer from your account at Ode financial Institution indicated on your check or to process t ho payment as a check transaction. If payment is processed as on oleetronk kind transfer, the tromfer will be For the amount of the check. When we use information from your check to make an eiectrank fund eonsler, kinds may be withdrawn from your account as won as the some day we revive your poymaht, and you will not receive your check bock from your financial Institution. The processing al your paymirrd may be delayed If you send cash, correspondence or other items with your payment, if you send the payment to any other address or )you use an snwbpe other than the one provided. Payments received in proper corm al our PracsuIng foci try by 5PM local time on any day will be credited to your Account as of that day. Payments received at our procoul faciON odor 5PM local time will be credited to your Account as of the nose day. l you have misplaced your envelope, send your payment to Discover, PO Box 6103, Card Stream, IL 60197.6103. Piwse allow 7.10 days for delivery, I your payment is returned unpaid, we reserve to right to resubmit it as an electronic debit. 'You can pay your minimum poyment or c greater amount over the t lephaa and you can set up automatic payments. Cal us at 1.800347-2683. You will bleed this siosomerc and yaw bank mcounf information. You must ensure bhai su8icienl kinds are available in your bank account, and all tanwcsons must comply with U.S. law. You will he asked to provide the first 5 digits of your account deterrent ZIP code. By erderling those numbers as your electronic you will he OR this authorization to allow us and your bank to deduct each payment you authorize from your bank account, and to initiate dstiY f eeredt ordrin b yo r bw* account, as applicable, to correct an error In the procesang of such payment. You must tell us the amount of each payment or you can sled tan amount such as the Minimum Payment Due or to New Balance on each sbtement. You can concef a payment however we must receive notice al host three business days In advance of the scheduled payhrent. You may notify us by phone of 1.800347.2683 or try muff at the address listed in the previous paragraph. l your payments vary in amount, we win tell you an each monthly sbhment when your payment will be mode and how much it will be. Your autamaBc payment amount may be leu than indkaed on the monthly statement based on credits or payments applied during the billing cycle. Ctedif Reporting. We may report Information about your Account to credit bureaus. Late paymards, missed payments, or other defaults an your Account may be reflected in your credo report. We normally repo" tw status and payment history alyour Account to credit reporting agencies each month. t yyoouu believe that our report is Inaccurate or Incomplete, please write us at do fallowing address: IXscover, PO Box 15316, Wilmington, DE 198505316. Pleo. Indicate your name, address, home telephone number and Account number. Paying Irdereds We begin to Impose Interest Charges on dl transactions from the Transaction Dote for die transaction shown on your lolling statement, uelau a eahsaclon Is passed b your Account after" close of the billing period in which N occurs, In which easewe begin to impose interest a urges an that transaction from the first day of the billing period in which it Is posted b your Account. We continue to impose Interest Charges until the dote you pry your -mire New Balance shown w your blWg statement by making ayments or Yount' credits. If you paid the New Bolome on your previous billing sbtemem by the heyrwM Due Date shown on that bdWg statement, we wip not impose Interest Ghorges on new purchases, that is, purchases first apOhs pearing on the Vrn sto b? stabdrheM or orhY?loMMon_ of a nqw rodent, paid tN POylMflt DIN Date OII your CuffMl Ffling Slalelwnl. WeeaB_ t_IIL ,•grgc? period, N is not leu than f5 days. 'then is no grace period on balance h-ansfers or cash advances. As more fully described in Ile section your Cardmsmber - - - - - Agreement filled 'How We Apply Payments,' we generally apply poymsnp to yyoouur Account based on the APR applicable to the balance of each transaction category. This means Oat tyahe do not pay the New Balance on on current bhlOng statement by Ohe Payment Due Date shown on that billing statement, ten, 'depending on to amount at your payment and the APRs on otwt balances, you may not get a grace period on new purchases. Minimum Inhered Charge. We will charge you a minimum Interest Charge of 5.50 for any billing period in which Interest Charges of less than $.50 would otherwise be imposed. Kyaw Account has an annual Fee, d will be billed at the beginning of each am kwsory year your Account is open. The amount of the he tenesnhf when tie his is billed. The amoral fire is not rates late unless you trolly w olhot you wish to close your Account within 30 days of the moiling or delivery date of the statement on which the Fee is billed. You will receive this refund wen It you use your Card during OWN period. How We Calcsstote Interest Charges Doily Balance Method (inducting current transactions): We figure interest Charges for each killing period. To do this: We calculate your Interest Charges separately For each balance subject to different terms (for example, standard purchases, standard cosh advenhces and each purchase, balance transfer and cash advance balance subject to promotional terms). We refer to these balances as Ironwction categories. We figure die 'daily balance' For each transaction category. To get the *daily bolonci we take the beginning balance for each day, odd any new eonsactbns anal fees and any Interest Charges accrued on IM previous day's defy balance. We ten subtext any credits andpoymsms and make other adjustments (including than adlusi ants required in tve section ltled'Paying Intama"). In cakulaing to daily balance for the Orst day at the billing period, we consider the 'previous day's doily balance' b how been your balance on the last day of your previous tilling period. This gives w the doily bounce for each transaelon category. We figure the Interesharges ea your Account by multiplying the daily balance for sach transaction category by its daily periodic rate, for each day the biding period. SEE REVERSE SIDE FOR IMPORTANT INFORMATION D' R VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unworn falsifications to authorities, that she is Natasha Szczygiel, Legal Placement Account Manager (Name) (Title) of DB Servicing_Co_rporation successor to DFS Services LLC servicing agent for Discover Bank, (Company) plaintiff herein, that she 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 her knowledge, information and belief. WWR# 9021713 Christopher PAU. Kohan 6011499423143799 DISCOVER BANK Plaintiff vs. RTSTOPHER P'U KOHAN TO THE PROTHONTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION .-Vlr??s, fat , +MBERLAIND Coij?' y PEW-IsYL?'A?11- Civil Action No. 11-3504 CIVIL PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant CHRISTOPHER PAU KOHAN above named, in the default of an Answer, in the amount of $8669.01 computed as follows: Amount claimed in Complaint Less payments / adjustments made Interest on the remaining principa $8043.80 from February 03, 2011 the interest rate of 19.4900 Attorney's fees TOTAL $8043.80 $0.00 1 balance of to May 31, 2011 per annum $500.21 $125.00 $8669.01 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: James C. ,42524 09021713 0A Pit SJS Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburg , PA 15219 And that the last known address of the D fendant is CHRISTOPHER PAU KOHAN 6 MANOR DR MECHANICSBURG, PA 17055 ?1 ?1.ob ?rcC ? Ct? S?1LLl9 t2? a. X07 ?? 1?? rte. ?yL??, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff Case No. 11-3504 CIVIL vs. CHRISTOPHER PAU KOHAN Defendant IMPORTANT NOTICE TO: CHRISTOPHER PAU KOHAN 6 MANOR DR MECHANICSBURG, PA 17055 Date of Notice: '511611( 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. By: Matthew Urban P.A.I. D.# 90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 (412) 338-7130 9021713 A PIT AJ4 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. CHRISTOPHER PAU KOHAN Civil Action No. 11-3504 CIVIL 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 , CHRISTOPHER PAU KOHAN 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: CHRISTOPHER PAU KOHAN 6 MANOR DR MECHANICSBURG, PA 17055 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 Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Jun-13-2011 07:07:41 -< Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency KOHAN CHRISTOPHER Based on the information you have furnished, the DMDC does not possess any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). A 14. MY, 1-t 0j(0j4j4 _ 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 httv://www.defenselink.mil/fag/pis/PC09SLDR.html. 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. 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 https://www.dmdc.osd.mil/appj/scra/popreport.do 6/13/2011 Request for Military Status Page 2 of 2 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:T08QVKDFFV https://www.dmdc.osd.mil/appj/scra/popreport.do 6/13/2011 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. CHRISTOPHER. PAU KOHAN Civil Action No. 11-3504 CIVIL NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following order of Judgment was entered against you on (xx) Assumpsit Judgment in the amount of $8669.01 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 Prothonotary B ? Y= PROTHONOTARY OR DEPUTY CHRISTOPHER PAU KOHAN 6 MANOR DR MECHANICSBURG, PA 17055 Plaintiff's address is: 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 11-3504 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK., Plaintiff (s) From CHRISTOPHER PAU KOHAN, 6 MANOR DRIVE, MECHANICSBURG, PA 17055 (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 GARNISHEE(S) as follows: PNC BANK, 105 NOBLE BLVD., CARLISLE, PA 17013 WELLS FARGO BANK, 604 E. HIGH STREET, CARLISLE, PA 17013 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 $8,669.01 Interest $175.28 Atty's Comm % Arty Paid $171.00 Plaintiff Paid Date: 11/18/11 L.L. $.50 Due Prothy $2.00 Other Costs: (Seal) REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 47437 IN' THE COURT OF COMMON P;JEAS OF CUMBERLAND COUNTY, PEIINSYLVANIA CIVIL DIVISION DISCOVER ;-,ANk Plai,. iff vs. C11RiST u'? iER PA?J KO AN D=: fendant(s) rNCBANK ?DS 00je- WELLS FARGO BANK LA- C>#-Garnishee(s) TO THE PROTHONOTARY: Civil Action Nc. ^1 11-3504 CIVIL V Y A"U" MZCIn. ?? I (CUS S l?l?d ? ?aa' l?sle? pw- l? o t3 h S CoG- l? sly (??- t 7o t3 PRAECIPE FOR WRIT OF EXECUTION Kindly iss ,c a `;-/rit of Execution in the above matter... r. , l . dirEk„ed to th( Sheriff of CUMBERLAND County: 2. 9,-,a,n?tCPrIISTC`?HERPAI.; KOI?AN Defendant 3. against r°NC BANti, WELLS FARGO B 4NK, , Garnishee t. Judgmem Amount $ $8,669.01 Les- Payments/credits received $ $0.00 Inte; °st $ $175.28 Casts S SUBTOTAL: $ $8,844.29 Costs (t:- added by Prothonotary): $ WF;I: I,MAN, W:"'NBERG & REIS CO., L.P.A. of ? ov C DD 111.0610,1, 5o , sl?1.00 By: -- - --j -- Willi,rr. T. Molczan, Esquir PA I.D #47437 WELTNIAN, WI;IT`IBERG & REIS CO., L.P.A. 1400 Koppers B!?ilding 136 Seventh Avenue 'i;;sburgh.. PA 152 i 9 (4:2)434-7955 ?. Scs z.L Cx-??oa??3C? W W R No. 9021713 Wl-?- w cz-?' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK. Plaintiff` vs. CHRISTOPHER PAtJ KOHAN Defendant(s PNC BANK ,VELLS FARCTO BANK. Barr., ;hee(,. ) No. 11-3504 Clk' 11, PRAECIPE FOR WRIT OF EXECUTION (BANK A'TT'ACH BENT ONLY) Fli_.ED ON BEI IALF OF 'laintiff COUNSI,I, OF 1' ECORD OF TINS PARTY: William T. Molczan, Esquire PA I.D. it47437 WELTMAN, "IANBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pitisbar,,h. PA 152 i 9 (412) 434-7955 W WR No. ';`021713 IN THE, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. CHRISTOPHER PAU KOHAN Defendant PNC BANK Garnishee No. 11-3504 PRAECIPE FOR JUDGMENT AGAINST GARNISHEE n #-? C' ! zrn =::0 r r- -v rn :0 U-, -<> .r ; a) o rz o ao• FILED ON BEHALF OF ac c3m Plaintiff y r cn ;7 COUNSEL OF RECORD OF THIS PARTY: Matthew D. Urban, Esquire PA I.D.#90963 Weltman, Weinberg & Reis Co. , L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#9021713 G ( .. k Je30qcjl0 ?? ato9 ?l? IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. CHRISTOPHER PAU KOHAN Defendant PNC BANK Garnishee Civil Action No. 11-3504 PRAECIPE FOR JUDGMENT AGAINST GARNISHEE TO THE PROTHONOTARY: Kindly enter Judgment against the Garnishee, PNC BANK, in the amount of $5637.25, which is the less than the amount Defendant owes to Plaintiff and which amount Garnishee has admitted owing to the Defendant, in answers to Interrogatories. WELTMAN, WEINBERG & REIS CO., L.P.A. By: Matthew D. Urban, Esquire PA I. D.#90963) Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#9021713 I hereby certify that the address of the Plaintiff is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219 And that the last known address of the Garnishee is: 105 NOBLE BLVD CARLISLE PA 17013 SIRLIN GALLOGLY & LESSER, P.C. By: Jon C. Sirlin, Esquire Identification No.: 17498 123 South Broad Street, Suite 2100 Philadelphia, PA 19109 (215) 864-9700 Attorney for Garnishee LC M.- ` . cn r rv '? CD BANK COURT OF COMMON PLEAS COUNTY OF CUMBERLAND vs. ; CHRSITOPHER PAU KOHAN and NO. 11-3504 PNC BANK, NATIONAL ASSOCIATION, GARNISHEE ATTORNEY I.D.#17498 BILL OF COSTS OF GARNISHEE, PNC BANK, NATIONAL ASSOCIATION Garnishee, PNC Bank, National Association, hereby bills the following costs to the fund attached, and will be satisfied therefrom as authorized by 42 Pa.C.S.A. Section 2503: Garnishee's fee pursuant to 42 Pa. C.S.A Section 2503: $350.00 Notary Charges: $ 0.00 Entry of Appearance: $ 0.00 Answers to Interrogatories: 0.00 Order to Discontinue or Satisfy: $ 0.00 Other: \ ?\ $ 0.00 JON C. W Attorne for i Costs are hereby taxed in the amount of $ this of 2012. PROTHON BY: ii-LO OFFiCE 4i 17 '1111E PR 0-1 HIONO TAR Y WELTMAN, WEINBERG & REIS CO., L.P.A. BY: James C Warmbrodt, Esquire I.D. No.42524 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 9021713 Attorney forPlainiEB 10 AN 11: 47 CUM8ERLANO COUNTY PENNSYLVANIA DISCOVER BANK vs. CHRISTOPHER PAU KOHAN and WELLS FARGO BANK Garnishee(s) Cumberland County Court of Common Pleas NO. 11-3504 CIVIL PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter discontinued and ended as to Garnishee(s), WELLS FARGO BANK. only. WELTMAN, WEINBERG & REIS CO., L.P.A. By Sworn to and subscribed Before me the S day anuary, 2012 AR COMMONWEALTH OF PENNSYLVANIA NotKW Seal Wayne Alma, Notary Public City of Pittsburgh, AUaghany County My Commission Expires June 28, 2014 Nlefnber. ae.,nsvlvanle Assodatlon NOtarjes aM,-Scl.so tA°•J e jc41036 as3a f J03s3to?$ SHERIFF'S OFFICE OF CUMBERLAND COUNTY .ny R Anderson ,leriff ,rug r,, Jody S Smith Chief Deputy Richard W Stewart Solicitor Discover Bank Case Number vs. 2011-3504 Christopher Pau Kohan SHERIFF'S RETURN OF SERVICE 11/30/2011 11:45 AM - Elizabeth Muller, 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, 105 Noble Blvd, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Beth Ann Eppley - Asst. V.P. Branch manager, personally thre( 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 December 1, 2011 to Christopher Pau Kohan at 6 Manor Drive, Mechanicsburg, PA 17055. 11/30/2011 09:51 AM - Shawn 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, 604 East High Street, Carlisle Borough, Carlisle, PA 17013, Cumberland County, by handing to Paul Fenton - Service Manager Officer, personally three true and attested copies of the Writ of Execution and made the contents there of known to him. The writ of execution and notice to defendant was mailed on December 1, 2011 to Christopher Pau Kohan at 6 Manor Drive, Mechanicsburg, PA 17055. 04/18/2012 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: $144.23 April 18, 2012 SO ANSWERS, RbNI`YY R ANDERSON, SHERIFF Z 3 Q =CC) GJ --4r r 54 ilee - $,2-50 C* 8l0 qM 0 a7yoa7 '? Te.p )+t. II"FC. WELTMAN, WEINBERG & REIS CO., L.P.A. BY: James C Warmbrodt, Esquire I.D. No.42524 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 9021713 Attor?wy for Plaintiff(s) ''?',? i°f? 23 Ph 1: ?3P 4 'UM BERL/iND COUNTY PENNSYLVANIA DISCOVER BANK vs. CHRISTOPHER PAU KOHAN and PNC BANK Garnishee(s) Cumberland County Court of Common Pleas NO. 11-3504 CIVIL PRAECIPE TO SATISFY ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter satisfied as to Garnishee(s), PNC BANK, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By. Sworn to and subscribed Before-me thef/- day of April, 2012 OTARY PUBLIC ?rlal Seat '•?•?r?yA Ross G. 9evan, Kota coM ? 'AIRY Public ODU vnv? kOV ]Sty -M.u,,2014 Jam C Warmbrodt Esquire Attev for Plaintiff Ct so .lo?r?sra %?a7q/97