HomeMy WebLinkAbout11-3580IN THE COURT OF COMMON PLEAS OF
CUMBERLAND, PENNSYLVANIA
Discover Bank
c/o DB Servicing Corporation
6500 New Albany Road East
New Albany, OH 43054
No. ) 1 5:5,3,6 3- Vi i
Y-1-1
Plaintiff
vs.
CIVIL ACTION - LAW
SHARON L SEIBERT
5060 CAMBRIDGE BLVD
MECHANICSBURG, 17050-8351
Defendant
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 is served,
by entering a written appearance, personally of by 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, 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
800-990-9108
ns
?? aS7So3
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND, PENNSYLVANIA
Discover Bank No.
c/o DB Servicing Corporation
6500 New Albany Road East
New Albany, OH 43054
Plaintiff
VS.
CIVIL ACTION - LAW
SHARON L SEIBERT
5060 CAMBRIDGE BLVD
MECHANICSBURG, PA 17050-8351
Defendant
AVISO PARA DEFENDER
USTED HA SIDO DEMANDADO/A EN LA CORTE. Si usted desea defender conta la
demanda puestas en las siguientes paginas, usted tienen que tomar acci6n dentro veinte (20) dias
despuds que esta Demanda y Aviso es servido, con entrando por escrito una aparencia
personalmente o por un abogado y archivando por escrito con la Corte sus defensas o objeciones
a las demandas puestas en esta contra usted. Usted es advertido que si falla de hacerlo el caso
puede proceder sin usted y un juzgamiento puede ser entrado conta usted por la Corte sin mas
aviso por cualquier dinero reclamado en la Demanda o por cualquier otro reclamo o alivio
solicitado por Demandante. Usted puede perder dinero o propiedad o otros derechos importante
para usted.
USTED DEBE LLEVAR ESTE PAPEL A SU ABOGADO ENSEGUIDA. SI USTED NO
TIENE UN ABOGADO, VAYA O LLAME POR TELEFONO LA OFICINA FIJADA AQUI
ABAJO. ESTA OFICINA PUEDE PROVEERE CON INFORMACION DE COMO
CONSEGUIR UN ABOGADO.
SI USTED NO PUEDE PAGARLE A UN ABOGADO, ESTA OFICINA PUEDE PROVEERE
INFORMACION ACERCA AGENCIAS. QUE PUEDAN OFRECER SERVICIOS LEGAL A
PERSONAS ELIGIBLE AQ UN HONORARIO REDUCIDO O GRATIS.
Cumberland County Bar Association
32 South Bedford Street
Carlisle PA 17013
800-990-9108
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND, PENNSYLVANIA
Discover Bank No.
c/o DB Servicing Corporation
6500 New Albany Road East
New Albany, OH 43054
Plaintiff
VS.
SHARON L SEIBERT
5060 CAMBRIDGE BLVD
MECHANICSBURG, PA 17050-8351
Defendant
CIVIL ACTION - LAW
COMPLAINT
1. The Plaintiff is Discover Bank, f/k/a Greenwood Trust Company (hereafter "Discover Bank"), an
FDIC-insured Delaware State Bank. The business address for legal action is DB Servicing Corporation,
6500 New Albany Road East, New Albany, OH 43054. DB Servicing Corporation is the servicing
affiliate of Discover Bank. Both Discover Bank and DB Servicing Corporation are wholly owned
subsidiaries of Discover Financial, an independent, publicly traded company.
2. The Defendant, SHARON L SEIBERT, is an adult individual, residing at:
5060 CAMBRIDGE BLVD
MECHANICSBURG, PA 17050-8351
3. At all relevant times, Discover Bank was, and is a bank chartered under the laws of the State of
Delaware.
4. At all relevant times, Defendant was the holder of a Discover Card credit card (the "Card") that
enabled Defendant to charge items to a Discover Card Account (Account Number: XXXXXXXX-XX-
8492) (the "Account").
5. At all relevant times, Defendant was the basic cardmember on the Account, and was responsible
for paying all amounts charged to the Account.
6. The Terms Level Agreement between the Discover Card Cardmember and Discover Card (the
"Agreement") was provided to Defendant during the time period in which the Card was utilized and
maintained by Defendant, and therefore, Defendant assented to the terms and conditions therein, and a
true and correct copy of the Agreement is attached hereto, and incorporated herein, as Exhibit "A".
7. By accepting and using the Card, Defendant agreed to all of the terms and conditions set forth in
the Agreement, including the following:
a. Defendant agreed that, as the basic cardmember, Defendant is liable for all amounts
charged to the Account.
b. Defendant agreed to make "Minimum Payment" (as that term is used in the Agreement)
due each month, for charges on the account, by the payment due date indicated on the monthly
billing statements mailed by or on behalf of Discover Card. True and correct copies of
statement(s) are attached hereto, incorporated herein, and collectively marked as Exhibit "B".
C. Defendant agreed that if the payment was not made by the payment due date indicated on
the monthly billing statements, Discover Card may assess additional fees per the terms of the
agreement:
d. Defendant agreed that in the event of default, Defendant would pay all reasonable costs,
including reasonable attorney's fees, incurred by Discover Card in collecting the balance due,
including finance charges and delinquency fees, and in protecting itself from any harm it may
suffer as a result of the default.
8. Defendant used the Card to charge various items to the Account.
9. Discover Card issued and sent to Defendant the Account Statements, which set forth in detail all
items charged to the Account, and the total amount due and owing by Defendant to Discover Card.
Count 1- Breach of Contract
10. Discover Card incorporates by reference the averments of paragraphs 1 through 9.
11. Defendant failed to make the minimum payment specified on the statements.
12. By reason of the foregoing, Defendant breached the Agreement with Discover Card.
13. As a result of the breach, Defendant is personally liable to Discover Card for the sum of
$14,617.00. See Exhibit "B" as previously identified and incorporated herein.
14. Despite due demand, Defendant has failed to pay Discover Card the sum stated in paragraph 13.
15. As a result of Defendant's failure to pay the amount that Defendant owes, Discover Card referred
its claim to outside attorneys for collection, and is entitled to collect reasonable attorney's fees from
Defendant.
16. By reason of the foregoing, Discover Card is entitled to judgment against Defendant for breach of
contract in the sum of $14,617.00, plus reasonable attorney's fees, costs and prejudgment interest.
WHEREFORE, Discover Bank demands judgment against Defendant on County 1 in the sum of
$14,617.00, plus reasonable attorney's fees, costs and prejudgment interest.
Count 2- Account Stated
(in the alternative of Counts 1 and 3)
17. Discover Bank incorporates by reference the averments of paragraphs 1 through 16.
18. Defendant used the Card to charge various items to the Account for which payment was never
made. Discover Card and/or its servicing affiliate DB Servicing Corporation. kept accurate records of all
debits and credits to the Account for the prior billing period.
19. Discover Bank mailed to Defendant monthly billing statements for the Account, which accurately
stated the previous balance, and the debits and credits to the Account for the prior billing period.
20. Defendant had, for many months, made payments on account of the billing statements or retained
the statements without payment.
21. Defendant's actions as set forth above constituted an account stated between the parties for the
sum of $14,617.00, which sum reflects the balance, less credits, if any which were applied prior to the
date of this complaint.
WHEREFORE, Discover Card demands judgment against Defendant on Count 2 in the sum of
$14,617.00, plus prejudgment interest and the costs of this action.
Count 3- Unjust Enrichment
(in the alternative to Counts 1 and 2)
22. Discover Card incorporates by reference the foregoing paragraphs 1 through 21.
23. As a result of the foregoing, Defendant received the benefit of Discover Card's extension of credit
in the amount of $14,617.00, without paying for same.
24. Defendant was aware of, apprehended and appreciated Discover Card's provision of credit by
reason of Defendant having made payments on the account of the Account statements received on and
after Defendant opened the account.
25. The reasonable value of the credit Discover Card provided Defendant is the sum of $14,617.00.
26. Discover Card is entitled to prejudgment interest on the outstanding balance from the statement
due date.
27. Discover Card believes and avers if the relief requested herein is not granted, Defendant will be
unjustly enriched at Discover Card's expense.
WHEREFORE, Discover Card demands judgment against Defendant on Count 3 in an amount to be
determined at trial.
Respectfully submitted,
Amy F. Doylb!EW.
PA Supreme Court ID 8704///?-
Schlee and Stillman, LLC.
Physical Address:
204 St. Charles Way. Unit E+-'+1',77
York. PA 17402
Processing/Mailing Address:
P.O. Box 251298
West Bloomfield, MI 48325
For Court(s)/Attorney(s): 248-851-6000 Ext.601
888-286-5001 (Phone)
443-588-0417 (Facsimile)
Counsel for Plaintiff
STATE OF OHIO
COUNTY OF FRANKLIN
VERIFICATION
I am a Legal Placement Account Manager for DB Servicing
Corpo tion, the servicing agent of Discover Bank, an FDIC insured Delaware State Bank located at
Discover Bank c/o DB Servicing Corporation., 6500 New Albany Road, New Albany, OH 43054.
1. I am employed by DB Servicing Corporation and am competent to testify to the matters stated in
the Complaint which are made on my personal knowledge, based upon the books and records of
the Plaintiff, and are true and correct to the best of my information knowledge and belief.
2. In the ordinary course of business and as a regular business practice, DB Servicing Corporation,
the servicing agent of Discover Bank, employees or representatives with knowledge of the
accounts compile business records memorializing account activity and transactions at or near the
time they occur.
3. Entries in the files and business record of Plaintiff are made contemporaneously with transactions
in order to preserve the accuracy of the transaction.
4. Plaintiffs files and business records are maintained by DB Servicing Corporation, the servicing
agent of Discover Bank.
5. I have access to the files and business records relating to this account.
6. There is now due and owing from Defendant, Sharon L Seibert, to Plaintiff, upon Account
Number XXXXXXXX-XX-8492, the amount of $14617.00, including credit(s) and
adjustment(s).
7. The documents attached to this affidavit, if any, are true and accurate copies of business records
regarding the Defendant's account.
8. Upon information and belief, the Defendant is not now, nor has been within 30 days hereof, in the
military service of the Unites States as defined in the Servicemembers Civil Relief Act as
amended nor an infant, incompetent, under mental defect or infirm.
9. Defendant is entitled to no known valid defenses, setoff or counterclaims, and further states that
written demand was made upon the Defendant.
I understand this verification is made subject to the penalties of 18 Pa. C.S. Section 4904, relating to
unsworn falsification to authorities-
e?
',-1 4126?
DISCOVER'
YOUR DISCOVER' BUSINESS
CARD ACCOUNT
CARDMEMBER.AGREEMENT ................Pages 1-14
The terms and conditions of your Account, including
how we calculate finance charges, our fees and an
Arbitration of Disputes section. You have the right to
r* t` the arbl&athn. provision w4h respect to your
newAccount within 30 days afterrecelving your card,
as explained In the 'Right to Reject Arbitration"
section at page 13.
PRIVACY POLICY .........................Pages 14-16
A summary of the personal information we collect,
whem }t tray bt 4harect-w9h tahers, aRd ifow we
safeguard the confidentiality and security of
information. You rnaylirnItoursharing of such
information with others as explalned in section 4 of
the Privacy Polky at page 15
DESCRIPTION OF COVERAGE ...............pages 16-25
The terms and conditions of the Common Carrier
Accident Insurance and the Primary Collision Damage .
Waiver that is provided at no. charge to you when
Iibu .use your Card to purchase airline or other
common.carrier tickets or rent an automobile.
GLOBAL TRAVELER'S' HOTUNE....................page 2s
The terms and conditions of this free travel assistance
benefit.
C2010 Dlaower Bar*, Member FM TL22EF.0210
1oDCMO_02841(_TL22er-02to_ooo8Zjeaaeranaa 1,2 MIMS 9Aea2AM I -
EXHIBIT "A"
CARDMEMBER AGREEMENT
Meese read this Agreement cud* before using your Diswve& Business
Card Account It oontais the terns aid corld8ors of your AcwuK some
of wMdn may have dneged from earlier matelek Povided to you. in the
evert of any d lfmwxss 8nk Agreement d doll c mtrel we rmpKt your
add m real See 1 o or imodoom Ti Arbitration p of ancl our sectl I oon Pia 11
bnduda a waiver of a number of rights, indrr o spa Jury
trial
The Right to bled Arbkmd m se tlom on pose 13
the pie
ye u wAM felow if you desNe to rejed the MW A, of Disputes
DEFBNTIONS................................................... 2
USING. YOUR ACCOUNT 2
YOW AQOeptance ofWsAgrwent ............................ 2
PasAW Uses ofYOur Aawunt ............................... 1
Prohibited Una of Your Amount ............................... 3
Pwdnaa and Cash Advaraes in Foreign Curerndes................ 3
Cash Adartm Trorisfes....: v ............ ............... 3
Balm
UnaudWdM Use ....................................... 4
Yom Credit Lines ............................................ 4
Authorized User Mori ft Spending Limits ........................4
MAKING PAYMENTS ............................................. 4
Morlt* B Ststement ................................... 5
NOW Autonot
q 5
Now Vlk :......... 5
Payment ................:................. S
....................................... 6
..:.......................................... 6
FINANCE CHANES ...............................................6
How Vh Ceknlate Periods Finance Cfiaryes ......................6
How%%Caks/aoeYourBalarw .............................. 6
Variable or Fired Nnteat Rates ................................ 7
Default Rate ...................:..:..........................7
Cah Advance 7rasadon Fee Finance Charges ................. 8
Balance Trarni a Trarsacdon.Fee Finance t mW ............. . . 8
Fondgrn Currengr a Firarke CFnarges .................8
MWrmm?n Firwrae 8
Acaount SeEUp Fee Finance Charge ...... . ... . ......:.......... B.
FEES ............ .....8
AnnnalFee .............:........ .. . S.
Returnned•Paymad Fee ..................................... 9
Returned Dbww Bnslness:Wrd Ow& Fee ............... ....... 9
DEFAULT CAFICl7LAiltNl ................ ......... g
Types AND of Default ...............................................9
of Default .............. :.... .................. 9
... ......... .....................................
PRNACY AND OUR COMMUNICATIONS wrrH YOU .................. 10
Our Privacy Policy ............................................10
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DISC(NVER
New Balance Minimum Payment Due
$14,227.51 $2,059.00
Payment Due Date
September 25, 2010
26 SDSN6A01 0011628
SEIBERT, SHARON L/MISS
5060 CAMBRIDGE BLVD
MECHANICSBURG PA 17050-8351
Address, e-mail or telephone change?
Go to Www.DiK*ver.com or print change in space above.
Account Number ending in 8442
Enter Amount Enclosed Below q
Please make check payable to Discover Card.
You. are overlimit. Pay the sum of the monthly
minmum payment plus the overlimit amount of
$1,927.51.
Go paperless and make your account
information more secure with password.
protected statements only you can access.
Learn more at discover.comlpaperless.
PO Box 71084 111 111111 If go 11 1# 1 Its If loll
CHARLOTTE NC 28272-1084
11111111111111111lr,11111IMIIlllif if 111111111ee1r,11111111111
000001986458144765522142275100000000205900
upening 1)a1 e: July 27, 2010 - Closing Date: August
I Discover More Card Account Summary Account number ending in 8492
Previous Balance $13,857,24
Payments And Credits 0.00
Purchases + 0.00
Balance Transfers + 0.00
Cash Advances + 0.00
Interest Charged + 345.27
Fees Charged + 25.00
New Ba ance $14,227..51
See Interest Charge Calculation section Following
transactions for detailed APR information
Credit Line $12,300,00
Credit Line Available $0.00
Cash Advance Credit Line $6,200.00
Cash Advance Credit Line Available $0.00
You may be able to avoid Interest Charges, see Additional
Important Information for details.
Bonue
Opening Cashback Bonus Balance
Now Cashback Bonus This Period
..- _---- ----_
Cashback Bonus Balance
To learn more, log in at www.Disco~.com
Anniversary Month
September
$ 0.00
+ 0.00
$ 0.00
3 Easy Ways to Contact Us
1. Access your account securely at www.Discovw.com
2. Call 1.B00DISCOVER (1-800.3472683)
Please have your Discover®card availa
3. Write to us at Discover, PO Box 30943,
Sah Lake City, LIT 84130
For TDD (Telecommunications Device for the Deaf)l
assistance, please call 1-800347-7449.
t6, 2010
page i of 2
Payment Information
Now Balance $14,227.51
Minimum Payment Due* $2,059.00
Payment Due Dote September 25, 2010
*Includes past due amount of $1,698.00
Late Payment Warning: If we do not receive your minimum
payment by the date listed above, you may have to pay a lots
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 29.99% variable.
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 wiill' and
additional charges balance shown on up paying on
using this card and this statement in estimated total of. .
each month you pay.., about...
Only the minimum 83 years $145,506
payment
If you would like information about credit counseling services,
call 1-800-347-1121.
EXHIBIT "B"
Manage Your Account Online at www.Discover.com
• Access Free online tools like Paydown Planner to create a plan
to pay down your balance securely access statements, pay
bills online and easily track all transactions
• Make your money worth moreSM -find easy ways to earn
and redeem cash rewards
• NEWI Access your account securely through your
mobile phone
Transactions
Trans. Post
Date Dater
Foes Aug 25 Aug 25 LATE FEE $ 25 00
TOTAL FEES FOR THIS PERIOD 25.00
interest Charged _. _
INTEREST CHARGE ON PURCHASES $ 345,27
IWTFRFCTrwApe--r nm rani Anuen.rrcc , 1^
DISCOVER
It pays to SEIBERT, SHARON[ L/MISS
JX$C1 'VVEK Account number ending in 8492
page 2 of 2
Interest Charge Calculation
Your Annual Percentage Rate (APR) is the annual interest rate on your account,
ANNUAL PERCENTAGE BALANCE SUBJECT TO INTEREST CHARGE
Current Billing Period: 31 days RATE (APR) INTEREST RATE
Purchases 28.99% $14,02159 $345.27
Cash Advances 28,99% $0 $0
V - Variable Rate
Additional important Information
Important Information. d there is more than one page to this billing statement, see the back of each page for additional important inlormotian
See your Cardmember Agreement. Your Cardmembor Agreement contains all the terms of your Account.
Last or stolen cards. Report immediately! Call 1-800-347-2683.
What To De Of You Think You Find A Mistake On Your Statement
t you think there is an error on your statement, write to us at. Discover, PO Box 30421, Sall Lake City. U T 841300421.
In your letter, give us the following information
Act-curd information. Your name and account number.
Dollar amount: The dollar amount of the suspected error
Description of Prabfem. If you think there is on error on your bill, describe what you believe is wrong and why you believe it is a mistake
You must contact us within 60 days ohm the error appeared on your statement
You must notify us of any potential errors in writing. You may toll us, but if you do we are not required to investigate any potential errors and you may have to
pray the amount in question.
While we investigate whether or not there has been an error, the following are true
We cannot try to collect the amount in question, or report you as delinquent on that amount
The charge in question may remain an your statement, and we may continue to charge you interest on that amount But, if we determine that we made a
mistake, you wdl not have to pay the amount in question or any interest or other fees related to that amount
While you do not have to pay the amount in question, you are responsible for the remainder of your balance
We can apply any unpaid amount against your credit limit.
Your Rights If You Are iDissatfaBed WMh Your Credit Card Purchases
11 you are dissatisfied 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 the merchant, you may have the right not to pay the remaining amount due on the purchase,
To use this tight, all of the following must be true
I The purchase must have been made in your tome state or within 100 miles of your current mailing address, and the purchase price must have
been more than $50 (Note: Neither of these are necessary if your purchase was based on an advertisement we merited to you, or it we own
the company that sold you the goods or services)
2 You must have used your credit cord far the purchase Purchases made with cash advances from an ATM or with a check that accesses your
credit cord account do not qualify.
3. You must not yet have fully paid for the purchase
if oil of the criteria above are met and you are still dissatisfied with the purchase, contact us in writing at Discover, PO box 30945,
;wit Lake 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 point, if we think you owe an amount and you do not pay we may report you as delinquent.
Payments. Send only your payment and the top portion of this statement in die envelope provided Do not send cash By sending your check as described
above, you authorize us to use information on your check to make an electronic fund transfer From your account at the financial institution indicated on your
check or to process the pa meat os a check transaction If payment is processed as on electronic fund transfer, the transfer will be for the amount of the check
When we use information ham your chock a make an electronic Fund transfer, funds may be wiilhdrown from your account as soon as the same day we teceive
your payment, and you will not receive your chock back from your financial institution
The processing of your payment may be delayed if you sera{ cash, correspondence or other items with your payment, it you send the payment to any other
address or if you use on envelope other than the one provided Payments received in proper form of our processing facility by 5PM local time on any day will
be credited to your Account as of that day. Payments received at our processing facility after 5PM local time will be credited to your Account us of the next
day. if you have misplaced your envelope, send your payment to Discover; PO Box 6103, Carol Stream, IL 60197.6103 Please allow 7-10 days for delivery
If your payment is returned unpaid, we reserve the right to resuomit it as an electronic debit.
You can pay your minimum payment or a greater amount over the telephone, and you can set up automatic payments. Coll us at 1.8003,17-2683. You will
need this statement and your bank account information You must ensure that sufficient herd: are available in your bank account, and all transactions must
comply with U.S. law. You will be asked to provide the first 5 digits of your account statement ZIP code. 8y entering lhose numbers as your electronic
signosure, you will be agreeing to tits out errization to allow us and your bank to deduct each payment you authorize from your bank account, and to initiate
debit or credit entries to your bank account, as applicable, to correct an error in the processing of such payment You must tell us the amount of each payment
or you can select an omaunt such as the Minimum Payment Due or the New Balance on each statement, You can cancel a payment, however we must receive
notice of bast three business days in advance of the scheduled payment You may natify us by phone at i-800347.2683 or by mail at the address listed in the
previous paragraph. N your payments vary in amount, we will tell you on each monthly statement when your payment will be made and how much it will be
Your automatic payment amount may be less than indicated on the monthly statement based on credits or payments applied during the balling cycle
Credit Repoaling. We may report information about your Account to credit bureaus, Lott payments, missed payments, or other defaults on your Account
may be reflected in your credit report, We normally report the status and payment history of your Account to credit reporting agencies each month. if you
believe that our report is inaccurate or incomplete, please write us at the following address iscover. PO Box 1!316, Wilmington, DE 19850-5316. Please
indicate your name, address, home talsphorse number and Account number.
Paying Interest: We begin to impose Interest Charges on all transactions from the Transaction Dale For die transaction shown on your 611irtg statement,
unless o tronuichon is posted to your Account after the close of the billing period in which it occurs in which case we begin to impose interest charges an that
transaction from t e first day of tae billing period in which it is posted to your Account We continue to impose Interest Charges until the date you pay your
entire New Balance shown on your billing statement by making ?yments or receiving credits. If you paid the New Balance on your previous billing statement
by tae Payment Due Dote shown on than billing statement, we wit not impose Interest Charges on new purchases, that is, purchases first appearing on the
current billing statement, or any portion of a now purchase, paid by the Payment Due Date on your current billing statement. We call this the "grace period.' It
is not less than 25 days There is to grace period on balonce hansfers or cash advances. As more fully described in the section of your Corchm mber
Agreement filled "How We Apply Payments," we generally apply payments to your Account based on the APR applicable to the balance of each hansaction
category. This means that if you do not pay the New Balance on the cuenf billing statement by the Payment Due Date shown on that billing statement, then,
depending on the amount of your payment and the APRs on other balances, you may not get o grace period on new purchases
Minimutn Interest Charge. We will charge you a minimum jnterest Charge of $ 50 lot any billing period in which interest Charges of lass than If 50
would otherwise be imposed.
Annual Fee. if your Account has an annual fee, it will be billed of the beginning of each anniversary year your Account is open Tire amount of the fee
appears on the statement when the fee is billed The annual too is not refundable unless you notify us that you wish to close your Account within 30 days of the
mailing or delivery dab of the statement on which the fee is bided. You will receive this refund even if you use your Card during that period
flow We Calculate Interest Charges - Daily Balance Method (including current transactions): We figure Interest Charges lot trach billing
period To do this
We calculate your Interest Charges separately for each balance subject to different terms (for example, standard purchases, standard cash
advances and each purchase, balance transfer and cash advance balance subject to promotional lerms) We refer to these bolances as
transaction categories.
We figure the 'daily balance" for each transaction category. To got the "doily balance' we take the beginning balance for each day, add any
new transactions and fees and any Interest Charges accrued on the previous doe's daily balance We then subtract any credits and payments and
make other adjustments (including those adjustments required in the section titled "Paying Interest"l. In calculating the daily balonce for the First
day of the billing period, we consider the 'previous day's doily balonce" to have been your balance on the lost day of your previous billing
period This gives us "doily balance For each transaction category
.
We figure the Inserest Charges on your Account by multiplying the daily balance for each transaction category by its daily periodic rate, for each
any in the billing period
The to-it Inituesl Charges for the billing period are the sum of the daily Interest Charges for each transaction category for each day during that
billing period
When we calculate daily balances, we add a new transaction as of the Transaction Dare shown on you, bittinq statement, unless the transaction is posted to
DISCOVER
New Balance Minimum Payment Due
$14,617,00 $2,429.00
Payment Due Date
October 25, 2010
26 SDSN6A01 0011629
SEIBERT, SHARON L/MISS
5060 CAMBRIDGE BLVD
MECHANICSBURG PA 17050-8351
Address, ti-mail or telephone change?
Go to www.Discover.com or print change in space above.
Account Number ending in 8492
Enter Amount Enclosed Below
Please make check payable to Discover Card.
You are overlimit. Pay the sum of the monthly
minimum payment plus the overlimit amount of
$2,317.00.
Go paperless and make your account
information more secure with password-
protected statements only you can access.
Learn more at discover.comlpaperless.
PO BOX 71084 111 11111111 $1 It IN lies till If
CHARLOTTE NC 28272-1084
111111111111111 11 IIIIIIIIIIIIIIII1111"L.l11II11 I I I IIIIIIIIII
000001986458144765522146170000000000242900
Opening Date: August 27, 2010 - Closing Date: September 26, 2010
Discover More Card Account Summary
Account number ending in 8492
Previous Balance
Payments And Credits
Purchases
Balance Transfers
Cash Advances
Interest Charged
Fees Charged
_ _
New Balance .._..
$14,227.51
0.00
+ 0,00
+ 0.00
+ 0.00
+ 354.49
+ 35.00
$1d,b17.00
See Interest Charge Calculation section following
transactions for detailed APR information
Credit Line $12,300.00
Credit Line Available $0.00
Cash Advance Credit Line $6,200.00
Cash Advance Credit Line Available $0.00
You may be able to avoid Interest Charges, see Additional
Important Information for details.
e.uarwLK ravllua Anniversary Month
September
Opening Cashback Bonus Balance $ 0,00
New Cashbock Bonus This Period + 0,00
Cashback Bonus Balance $ 0.00
To learn more, log in ai www.Discover.com
3 Easy Ways to Contact Us
1 Access your account securely at www.DiscwAw.com
2. Call 1.800-DISCOVER (1.800.347-2683)
Please have your DiscoverOcard available.
3. Write to us at Discover, PO Box 30943,
Salt Lake City, UT 84130
For TDD (Telecommunications Device for the Deaf)
assistance, please call 1.800-347.7449.
page 1 of 2
Payment Information
New Balance $14,617.00
Minimum Payment Due' $2,424,00
Payment Due Dote October 25, 2010
'Includes past due amount of $2,059.00
Late Payment Warning: If we do not receive your minimum
payment by the date listed above, you may have to pay a late
fee of up to $35.00 and your purchase and balance transfer
APRs for new transactions may be increased up to the Penalty
APR of 29.99% variable.
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 payoff the And you will end
additional charges balance shown on 'up paying on
sing this card and this eatement in esirmoted total of...
each month you pay... about...
Only the minimum 83 years $146,230
payment
If you would like information about credit counseling services,
call 1-800-347-1121 .
Manage Your Account Online at www.Discover.com
• Access free online tools like Paydown Planner to create a plan
to ppay down your balance, securely access statements, pay
bills online and easily track all transactions
• Make your money worth moresm-find easy ways to earn
and redeem cash rewards
• NEW Access your account securely through your
mobile phone
Transactions
Trans. Post
Date Date
Fees Sep 25 Sep 25 LATE FEE $ 35.00
TOTAL FEES FOR THIS PERIOD 35.00
Interest Charged INTEREST CHARGE ON PURCHASES $ 354.49
INTFUSTrHARr;F nN r'ARH AnVANCFt nnn
DIt`? \f?d` If pays to SEIBERT, SHARON L/MISS
A
b
d
?? T [l ? ccount num
er en
ing in 8492
page 2 of 2
Interest Charge Calculation
Your Annual Percentage Rate (APR) is the annual interest rate on your account.
ANNUAL PERCENTAGE
Currant tinning Period: 31 days RATE (APR( BALANCE SUBJECT TO INTEREST CHARGE
INTEREST RATE
Purchases 28.99% $14,398.31 $354.49
Cash Advances 28.994a $0 $0
V = Variable Rate
Additional Important Information
Important Information. If there is more than one page to this billing statement see the back of each page for additional important enformahon
See your Cardmember Agreement. Your CardmeFnbei Agreement contains all the terms of your Account.
Lost or stolen cards. Report immediately! Coll 1-800-347.2683.
Whet To Do If You Think You fksd A Mistake On Your Statement
if you think there is on error on your statement write to us at Discover, PO Box 30421, Sall Lake City, UT 84130-0421,
in your lerter, give us the following information
Accow+f irdannohorr, Your Frame and account number.
Dndlar arrounlr Ore dollar amount of the suspected error.
Description of Problem: if you think there is an error on your bill, describe what you believe is wrong and why you believe it is a mistake
You must contact us within 60 days offer the error appeared on your statement.
You must notify us of any potential errors in writing. You may callus, but if you do we are not required to irsvestigute any potential errors and you may have to
pay the amount in question.
While we investigate whether or not there has been an error, the following are True
We cannot try to collect the amount in question, or report you as delinquent on that amount
The charge in question may remain on your statement, and we may continue to charge you interest on that amount But, if we determine that we mode a
mistake, you will not hove to pay the amount In question or any interest or other fees related to that amount.
While you do nol have to pay the amount in question, you are responsible for the remainder of your balance
We can apply any unpaid amount against your credit Limit
Your Rights If You Are Dissatisfied Wbh Your Credit Card Purchases
If you are dissatisfied with rise goods or services thor voo have purchased with your credit card, and you have tried in good faith ro correct the
problem with the merchant, you may have the right not to pay the remaining amount due on the purchase.
To use this right, all of the following must be true -
1 The purchase must have been mach in your home store or within 100 miles of your current mailing address, and the purchase price must have
been more than $50 (Note: Neither of these are necessary if your purchase was based on an advertisement we mailed to you, or it we own
the 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 an ATM or with a check that accesses your
credit card account do not qualify.
3 You must nor yet hove fully pad for the purchase
if all of the criteria above are met and you are still dissatisfied with the purchase contact is in writing at Discover, PO Box 30945.
Sall Lake City, UT 841300445
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 point, if we think you owe on amount and you do not pay we may report you as delinquent.
Payments. Send only your payment and the top portion of this statement in the envelope provided. Do not send cash. By sending your check as described
above; you authorize us to use information on your check to make an electronic fund transfer from your account at the financial institution indicated on your
check at to process the payment as a check transaction If payment is processed as an electronic fund hori the transfer will be for the amount of the check
When we use information from your check to make an electronic fund transfer, funds may be withdrawn Irani your account as soon as the usme day we receive
your payment, and you will not receive your check bock from your Financial Institution.
The processing of your paymenl may be delayed It you send cash, correspondence or other items with your payment. 4 you send the payment to any other
address or 4 you use an envelope other than the one provided. Payments received in proppeer torm at our processing facility by 5PM local time on any day will
be credited to your Account as al that day, Payments received ar our processing focility offer 5PM local Time will be credited to your Account as of the next
day If you have misplaced your envelope, send your payment to Discover, PC) Box 6103, Carol Stream, IL 601976103. Please allow 7.10 days for delivery
.
If your payment is returned unpaid, we reserve thee right to resubmil it as an elechanec debit
You can pay your minimum payment or a greater amount over the telephone, and you con setup automatic payments. Callus at 1.800347-2683 You will
need this statement and your bank account information. You must ensure that sufficient funds are available in your bank account and all transactions must
comply with U S law. You will be asked to provide the first 5 digits of your account statement ZIP code. By entering terse numbers as your electronic
signature, you will be agreeing to this authorization to allow us and your bank to deduct each poymeni you authorize from your bank account, and to inifiote
deb t or crssdn enrries to your bank account, as applicable, to correct an error in the processing of such payment You must roll us the amount of each payment
or you can select an amount such as the Minimum Payment Dollar the New Balance on each statement You con cancel a payment, however we most receive
notice at least ti" business days in advance of the scheduled payment You may notify us by phone at 1-BOD,347-2683 or by moil at the address listed in tie
previous paragroplh if your payments vary in amount, we will fell you on each monthly statement when your payment will be made and how much if will be
Your automatic payment amount rroy be less than indicated on the mondrfy statement based on credits or payments applied during the billing cycle
Credit Reporting. We may report information about your Account to credit bureaus. Late payments, missed payments, or other defoulh. on your Account
maybe reflected in your credit report We nornally report the status and payment history of your Account to credit reporting agencies each month. If you
believe that our report is inaccurate or incomplete, please write us at the following address: Discover, PC) Box 15316. Wilmington, DE 1 9850 53 16 Please
indicate your name, address, home telephone number and Account number
Paying Interest: We begin to impose Interest Charges on all transactions from the Transaction Date for the transoctian shown an your billing stalernent
unless a transaction is posted to your Account after the close of the billing period in which it occurs, in which case we begin to impose interest charges on that
sransaclion from the firs) day of the billing period in which if is punted to your Account We continue to impose Inferest Charges until the date you pay your
entire New Baance shown on your billing statement by making payments or receiving credits if you paid the New Balance on your previous billing statement
?ir the Payment Due Dole shown on that billing statement, we w'11 not impose Interest Charges on new purchases, that is, purchases first apPpearing on The
current telling statement, or any portion of a now purchase, paid by the Payment Due Dale on your current billing statement. We call this I e'grace period " it
is not less than 25 days There is no grace period on balance transfers or cash advances As more fully described in the section of your Cardmember
Agreement titled "How We Apply Payments," we generally apply payments to your Account based an the APR applicable to the balance of each transaction
e,oeegmy This means that S you do not pay the New Balance on the current billing statement by the Poyrrrenr Due Date shown on that billing siatensent, then,
depending on the amount of your payment and the APRs on other balances, you may nor gel a grace period on new purchases.
Minimum Interest Charge. We will charge you a minimum interest Charge of $ 50 for any billing period in which interest Charges of less man $ 50
would otherwise be imposed
Annual fee. 11 your Account has an annual fee, it will be billed at the beginning of each anniversary year your Account is open. The amount of the fee
appears on the starerr ont when the fee is billed. The annual lee is not refundable unless you notify us that you wish to close your Account willim 30 days of the
nailing or delivery dare of the statement on which the lee is billed. You will receive this refund even if you use your Card during that period
How We Calculate Interest Charges - Daily Balance Method (including current transactions): We figure interest Charges for earl billing
period. To do this
We calculate you= Interest Charges separately for each balance subject to different terms (for example, standard purchases, standard cash
advances and each purchase, balance transfer and cash advance balance subject to promotional tern,;. We refer to these balances m
transoction cotegories.
We figure she "daily balance" for each transaction category To get the 'daily balance" we take the beginning balance for each tiny, odd any
new rrnnsochons and fees and any interest Charges accrued on I previous day's daily balance. We then subtract any credits and payments and
make other adjustments (including those adjustments required in the section titled "Paying Interest"). In calculating the daily bolone c for the first
day of ri?e billing period, we consider the 'previous day's doily balance' to tom been your balance on the last day of your previous billing
period This gives us the doily balance for each transaction category.
We figure the Interest Charges on your Account by multiplying the daily balance for each hansoction category by its doily periodic rote for each
day in the billing period.
The total !merest Charges for the billing period are the sum of the doily Interest Charges for each transaction category fox each day dining Ihat
billing pefloo
When we calculate daily balances: we add a new transaction as of the Tionsoction Dare shown on your billing statement, unless the transaction is posted to
`'cD New Balance Minimum Payment Due Account Number ending in 8492
DISC YGR $0.00 $2,722.00 Enter Amount Enclosed 3elow
_-..___ __....-.-_._---..._
Payment Due Date
Octo6er 28, 2010 -----?
30 SDSN6A01 0011630
SEIBERT, SHARON L/MISS
5060 CAMBRIDGE BLVD
MECHANICSBURG PA 17050-8351
Address, e-mail or telephone change?
Go to www.DIscovercom or print change in space above.
Go paperless and make your account
information more secure with password-
protected statements only you can access.
Learn more at discover.comlpaperiess.
PO BOX 6103 111 loll lifM11111111Lu11
CAROL STREAM IL 60197-6103
IIIIIIIloilo 1111111111111I1II111111III1f111IIlIIltkf11111I1111
000001986458144765522000000000000000272200
Opening Date: September 27, 2010 - Closing Late: 5
Discover More Card Account Summary Account number ending in 8492
Previous Balance $14,617.00
Payments And Credits 14,617.00
Purchases + 0.00
Balance Transfers + 0.00
Cash Advances + 0.00
interest Charged + 0.00
Fees Charged + 0.00
New Balance - ^ -- $0.00
See Interest Charge Calculation section following
transactions for detailed APR information
Credit Line $12,300.00
Credit Line Available $0.00
Cash Advance Credit Line $6,200.00
Cash Advance Credit Line Available $0.00
1.0511"IDaCK oonus Anniversary Month
September
Opening Cashbock Bonus Balance $ 0.00
New Cashbock Bonus This Period + 0.00
Cashback Bonus Balance $ 0.00
10 team mote, log in at www.D'Iscover.com
tptember 30, 2010
page of i
Payment Information
New Balance $0.00
Minimum Payment Due $2,722.00
Payment Due Date October 28, 2010
Late Paynant Warning: If we do not receive your minimum
payment by the date listed above, you may have to pay a late
fee of up to $35.00 and your purchase and balance transfer
APRs for new transactions may be increased up to the Penalty
APR of 29.99% variable.
Manage Your Account Online at www.Discover.com
• Securely access statements and free online tools, pay bills
online and track and view all transactions simply and easily
• Make your money worth morel-find easy ways to earn
and redeem cash rewards
• NEWT Access your account securely through your
mobile phone
3 Easy Ways to Contact Us
1. Access your account securely at www.Discovvr.com
2. Call 1-B00-DISCOVER (1-800.347-2683)
Please have your Discovers card available.
3. Write to us at Discover, PO Box 30943,
Salt Lake City, UT 84130
For TDD (Telecommunications Device for the Deal)
assistance, please call 1.800-347-7449.
Transactions
Payments and Credits
Trans. Post
Date Date
Sep 30 Sep 30 INTERNAL CHARGE-OFF
$ -14,617.00
Fees TOTAL FEES FOR THIS PERIOD $ 0.00
Interest Charged TOTAL INTEREST FOR THIS PERIOD $ 0.00
2010 Totals Year-to-Date
TOTAL FEES CHARGED IN 2010 $ 294.00
TOTAL INTEREST CHARGED IN 2010 2,869.35
Interest Charge Calculation
Your Annual Percentage Rate (APR) is the annual interest rate on your account.
ANNUAL PERCENTAGE BALANCE SUBJECT TO INTEREST CHARGE
CrarrM alt B"g Period: 4 days RATE (APR) INTEREST RATE
Purchases 28.99% $0 $0
Cash Advances 28.999'0 $0 $0
V = Variable Rate
. N
hnron Seibert
5060 Cambridge Blvd
Mechanicsburg, PA 17050
Defendant
Court of Common Pleas
3
illl c?P9; 21 FP} Z-
r..IMBERL AN@ COUNTY
?Et}NSYLVANIA
State of (PA) (Cumberland) County
Discover Bank
c/o DB Servicing Corporation
6500 New Albany Road East
New Albany, OH 43054
Plaintiff
Sharon Seibert
5060 Cambridge Blvd
Mechanicsburg, PA 17050
5
Case number: 11-3480
Defendant
Sharon Seibert (Defendant) hereby answers the complaint of
CITIBANK, (Plaintiff) for its self atone as follows and generally
denies the allegations due to the complaint based on lack of
information and belief.
(Financial Hardship)
Due to a serious financial crisis, defendant does not have sufficent
funds to pay the full amount of undisputed debt, if any.
Due to having to retire because of medical reasons (several knee
ciirnsmries, decression. high blood pressurel. ! only mf?A P
3nnrnvimntA1v TAAA nn n month nnri that nneme to r ksif,
P'4zz
r-i-r+,+-.4 rsr-. rl r. vra va r,i ?f ,r.??c•rfa rab?_: iar>'^a i4'insv, ?rrr?r = ?: _-. s_. s-ir ?+: sar.?s :?:
,-a- ?:? ?t3.r?. s°z ? i _$ :R i_# L ?., t. :? /:; ;,r;r }r_m #e ?s? ?Lse aa?. ?r ?=??.?? .??.# ??
h??fa ?n? ?t1??f :?larrra??inn hn? rynt#art en ?,?? #h?? th?.f i??c# ir?t?r:3?Lcar?
rte Y-t ?rritmM if tNr, :Z +Iff uac n ^?4"1 f_r^ Ce Y:f'i4C` '3 f"1 L
ret nn nnvia+_-r hill b# #ha r-t irran4 fima I non nlcn nninr± thr? ? n raga a
L, ?r c is?r nnr3 eiatainn hn#k n e-ni tnt.-ainr nrN,-4 n ?NLi-tr hin#rief :-4- ? Ica #n rye=
mn#har nnccinri nuin 1 nn hA err h I CI4h of thic tram -mnr4 I hni^i #nIran e nrca
t11d??P??f'1??? ?1?ftar:t°!??# Y'a?rle?c,c#c #F;?#
=.-#a?tt " --r it {= ?(s' !
iit"4{4 {3}? ?ru
t
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W St
Solicitor
Discover Bank
vs.
Sharon L. Seit
SHERIFF'S RETURN OF SERVICE
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
CUFF OF - _ SrERIFF
F ILEC-OFFICE
OF THE PRO`6'I-ONOIAK"(
2011 APR 21 AM 10: 13
C,UMBERLA U i:Ci Ii
PENNSYLVANIA
Case Number
2011-3580
04/14/2011 07:3 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on April
14, 011 at 1930 hours, he served a true copy of the within Complaint and Notice, upon the within named
defe dant, to wit: Sharon L. Seibert, by making known unto herself personally, at 5060 Cambridge
Bou vard, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time
han ing to her personally the said true and correct copy of the same.
SHERIFF COST:
April 18, 2011
00
i? _."?
STEPHEN BPENDER, DEPUTY
SO ANSWERS,
oZ'
RON R ANDERSON, SHERIFF
'cj countySultB Sheriff. T eleosoft . Inc.
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 10-3580 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due TAYLOR MADE GOLF COMPANY INC. Plaintiff (s)
From JUSTIN L. LAMASON INDIVIDUALLY TRADING AS GOLF PRO-CHAMBERSBURG
CC AND JUSTIN L. LAMASON AS PERSONAL GUARANTOR AND JENNIFER LAMASON AS
PERSONAL GUARANTOR, 1 ASH DRIVE, MECHANICSBURG, PA 17050
(1) You are directed to levy upon the property of the defendant (s)and to sell LEVY UPON ALL
PERSONAL PROPERTY OF THE ABOVE-LISTED DEFENDANTS AT THE ABOVE
ADDRESS IN CUMBERLAND COUNTY, INCLUDING BUT NOT LIMITED TO
FURNITURE, JEWELRY. ELECTRONICS, SUPPLIES, ETC..
(2) You are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GARNISHEE(S) as follows:
M&T BANK, 1 WEST HIGH STREET, CARLISLE, PA FOR ANY ACCOUNTS UNDER
DEFENDANTS NAMES
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$31,903.73
L.L. $.50
Interest FROM JUDGEMENT 12-26-11 - $5.25 PER DIEM - $661. 50
Atty's Comm 5 %$1,595.19 Due Prothy $2.25
Atty Paid Other Costs
Plaintiff Paid $222.50
Date: January 9, 2012
David D.-Buell, Prothqnot
(Seal) By:
Deputy
REQUESTING PARTY:
Name JEFFREY L. TROUTMAN, ESQUIRE
Address. KODAK & IMBLUM, P.C.
P.O. BOX 11848
HARRISBURG, PA 17108
Attorney for: PLAINTIFF
Telephone: 717-238-7159
Supreme Court ID No. 53984
C 33; - , PRAECIPE FOR WRIT OF EXECUTION - (MONEY JUD NWJ -arn
P.R.C.P. 3101 to 3149
j_j
TAYLOR MADE GOLF COMPANY INC.
Plaintiff
vs
JUSTIN L. LAMASON individually trading as
GOLF PRO-CHAMBERSBURG CC and
JUSTIN L. LAMASON as personal guarantor
and JENNIFER LAMASON as personal
guarantor,
1 ASH DRIVE
MECHANICSBURG, PA 17050
DEFENDANT(S)
IN THE COURT OF CO
Cumberland COUNTY,
A
Writ No. .mac :'er@ 20
No. 2010-03580 Term 20 10
Amount Due
8/22/11 jdmt ............. $ 31,903.73
Interest from jdmt -12/26/11
5.25 per diem ............... $ 661.50
Atty's Commission
5% statutory rate .......... $ 1,595.19
Costs (to be determined) $
TO THE PROTHONOTARY OF SAID COURT: ISSUE WRIT OF EXECUTION IN THE ABOVE MATTER,
(1) Directed to the Sheriff of CUMBERLAND County, Pennsylvania
(2) against JUSTIN L. LAMASON i/ a/ t/ a GOLF PRO-CHAMBERSBURG CC and JUSTIN
L. LAMASON as persona guarantor and JENNIFER LAMASON as persona guarantor,
een ants;
(3) and against
arrus ee s ;
(4) and index this writ
(a) against JUSTIN L. LAMASON i/a/t/a GOLF PRO-CHAMBERSBURG CC and JUSTIN
L. LAMASON as persona guarantor and JENNIFER LAMASON as persona guarantor
Defendant(s) and
(b) against
arrusneeks),
as a lis pendens against the real property of the defendant(s) in the name of the Garnishee(s) as follows:
(Specifically describe property and note any specific direction to Sheriff) Furnish 4 copies for real estate levy):
LEVY UPON ALL PERSONAL PROPERTY OF THE ABOVE-LISTED DEFENDANT(S) AT THE ABOVE ADDRESS IN
CUMBERLAND COUNTY, INCLUDING BUT NOT LIMITED TO FURNITURE, JEWELRY, ELECTRONICS, SUPPLIES, ETC.,
AND GARNISH M & T BANK,1 W. HIGH STREET, CARLISLE, PA, FOR ANY AND ACCOUNT(S) UNDER DEFENDANT(S)
NAME(S).
(3(5) Exemption has (not) been waived.
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Dated 12/22111 N
rt . Kodak, Esquire
PO Box 11848
Harrisburg, PA 17108
(717) 238-7159
40. •6? ?`?? Attorney For Plaintiff(s)
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OF THE PROTNO OTA,R Y
" _' 112 JAN -6 PM 2: 4 !
CUMBERLAND COUNTY
PENNSYLVANIA
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NOTE
Under paragraph(]) when the writ is directed to the sheriff of another county as authorized by Rule 3103(b), the county should be indicated.
Under Rule 3103(c) a writ issued on a transferred judgment may be directed only to the sheriff of the county in which issued.
Paragraph (3) (above should be completed only in a named garnishee is to be included in the writ).
Paragraph (4)(a) should be completed only if indexing of the executions in the county of issurance, is desired as authorized by Rule 3104(a). When the writ issues to
another county indexing is required as of course in that county by the prothonotary. See Rule 3104(b).
Paragraph (4xb) should be completed only if real property in the name of the garnishee is attached and indexing as a lis pendens is desired. See"Rule 3104(c).