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Home My WebLink About11-4262THE lr"? FILED-OFF PPS ck IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs CHRISTOPHER VANBREDERODE Defendant No: //- 4?1X?z ? /V? /I 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 09089759 C A Pit CXC ?'?a7s£l03?z7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No CHRISTOPHER VANBREDERODE Defendant COMPLAINT AND NOTICE TO DEFEND You have been sued in court. If you wish to defend against the claims set forth in the following pages, you must take action within twenty (20) days after this complaint and notice are served, by entering a written appearance personally or by an attorney and filing in writing with the court your defenses or objections to the claims set forth against you. You are warned that if you fail to do so the case may proceed without you and a judgment may be entered against you by the court without further notice for any money claimed in the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff, 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 VANBREDERODE 18 W LOCUST ST MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX2278 . 4. Defendant made use of said credit card and has a current balance due of $3745.73 , as of July 31, 2009 . 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 28.990% per annum on the unpaid balance from July 31, 2009 . 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 VANBREDERODE INDIVIDUALLY , in the amount of $3745.73 with interest at the rate of 28.990% per annum from July 31, -009 plus attorneys' fees of $125.00 , and costs. WEINBERG & REIS CO., L.P.A. JFAX:41 War zo t,42524 th Avenue, Suite 1400 h, PA 15219 -7955 338-7130 C A Pit CXC This law firm i s a debt collector attemVing to collect this debt for our client and any information obtained will be used for that purpose. DISC VER $$0 w 00 Balance 31 SDSN6A01 0000977 CHRISTOPHER VANBREDERODE 18 W LOCUST ST MECHANICSBURG PA 17055-6333 Go paperless and make your account information more secure with password- protected statements only you can access. Learn more at discover.com/paperless. PO BOX 6103 Illnrllrrlloll r,uIIIIII A CAROL STREAM IL 60197-6103 Address, e-mail or telephone change? Print change in space Ipill llnnulllrlulnrlrllur,rllllunrll1Il1111 11111 11 above, or go to Discover.com. Print your e-mail address to EXHIBIT receive important Account information and special offers. 000001986458502060326000000000000000080000 Discover Motiva Card Account Summary Closing Date: July 31, 2009 page t of 1 Account number ending in 2278 Previous Balance $3 745.73 ;Payment Due Date August 26, 2009 Payments And Credits , 3 745.73 'Minimum Payment Due $800.00 Purchases , + 0.00 Credit limit $3,000.00 Cash Advances + 0 00 :Credit Available $0.00 Balance Transfers . + 0.00 Cash Credit Limit $1,500.00 Finance Charges + 0.00 :Cash Credit Available $0.00 New Balance $0.00 Cashback Sonuse Opening Cashback Bonus Balance $ 0.00 New Cashback Bonus This Period + Q,QQ Cashback Bonus Balance $ 0.00 Ccshbai:k Boriiii9 Anniversary Month: June .How Can We Hel You? p 'visit (];acaver cam to pay your big for no c,:*, vi.w our latest Account information, earn and redeem rewards and more ;It's your choice - 3 ways to help 2. Call 1-8004DISCOVER (347-2683) for fast, easy self-service Please have your Discover Card available. options or to speak with a Customer Service Account Manager ,For TDD (assistance for hearing impaired) see reverse side 3. Write us at Discover Card, PO Box 30943, Sale lake City, UT 84130 Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence. Trans, Post Dante Da Payments and Credits Jul 31 Jul 31 INTERNAL CHARGE-OFF $ 3,745.73 ffWLV Charge Summary Average Dail Daily P i d Nominal ANNUAL PERCE ANNUAL Periodic Transaction Fee y alances er o ic Rates NTAGE RATES PERCENTAGE RATES FMS FRMNCE !current billing period: 8 days Purchases $0 Cash Advances $0 0.07942% 0 07 28.99% F 28.99% $0 $0 . 942% 28.99% F 28.99% $0 $0 ;The rates that apply to your Account are either fixed (F) or they may vary (VI as noted above Minimum Payment Due Account Number ending in 2278 S800.00 Enter Amount Enclosed Below Payment Due Date $ August 26, 2009 Important infonruton. If there is more than one page to this billing statement. we the back of each page for additional important information. inn See your CarcimemberAgeemerd. Your Carhnember Agreement contains at the terms of your Account- co Lost or slolan cads. Report Immediately! Cat 1.888.347.2683. z D BflNnp Rights Summary. In Case of Errors or Questions About Your Bill: 11 you think your bit is wrong, or t you need more information about a transaction on your bit to us on a ? separele sheet of paper at Discover, PO Brix 30421, Sat Lake City, Uifi5730-0421, as soon as possible. We must hear horn you no latest Uhah 60 days after we sent you u the fret bit on , the which the error or r bl d Y l h p em appeare o . ou can te ep one us, but doing so wit! not preserve your rights. In your letter. give us the fopawng nformation: Your name and Account number. Th d h ll f N o e ar amount o t e suspeued error. Describe the error and explain. if you can, wiry you believe there is an error. t you need more information, describe the item you are unsure about. N You do not have lo pay arty amount in We" while we are investigating, but you are SON obligated to pay the pats of your bill that are not in question. While we investigate you question. we cannot report you as delinquent or take any action to collect the amount you question. Special Rule for Credit Card Purchases: If you have a problem with the quality of goods or services that you purchased with a credit card, and you have tied in good faith to correct the problem with the merchant you may not have to pay the remaining amount due on the goods or services. You have this protection only when the purchase price was more than SW and the purchase was made it your home stale or with 100 miles of your mailing address. (t we own or operate the merchant or t we nailed you the advertisement f r t d , o he goo s or services, at purchases are covered regardless of the amount or location of purchase.) Payments. Send only your payment and the top portion of he 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 amount at the fnaxial institution indicated on your check or to process the payment as a check transaction. If paymem is processed as an electronic kind mangler. the transfer wilt be lathe amount of the check When we use informati h k . am Yourdnec on to make an sledrouc fund transfer, kinds may be withdrawn from your account as soon as the same day we receive your payment, and you will not receive your Mock back iron your financial Institution. The processing of your payment may be delayed if you send cash, correspondence or other items with your payment, t you send the payment to any other address ail you use an em cope other dlarhihe one provided. Payments received in proper krm at our processing facility by 5PM local time on any day will becreddedto your Account as of that day. Payments received at our processing facility awe 5PM local tree wig be credited to your Account as of the next day. If you have misplaced your envelope, send your payment to Discover, PO Box 6103, Cad, Stream, IL 601978103. Please allow 7-10 days for delivery. If your payment's returned unpaid, we reserve the right to resubmit it as an elednonic debit You can pay your minimum payment or a greater amount over the telephone, aid you can set up automatic payments. Call us at 100.347.2683. You will need this statement and your bank aemuM nl'arrnaton. You rust enure that sufficient funds are available in your bate account, and all transactions must comply with U law S You wig be ask d b id ' . . . prov e e the first 5 digits ol you account statement 23P 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 payment you authorize from you bank account and to Mass debit or cred8 entries to your bank amount as applicable to correct th i , . an star n e processing of such payment, You must tell us the amount of each payment or you can select an amord such as Me Minimum Payment Due or the New Balance on each statement. You can cancel a payment: however we must receive notice at least three business days in advance of the scheduled payment. You may notify us by phone at 1400-347.2683 or by mail at the address hail in the previous paragraph. If you payments vary in amount we will tell you on each monthly statement when you payment will be made and taw much it will b Y e, our automatic payment amount may be less than indicated an the monthly statement based on credits or payments applied dung the biting cycle. Credit Reporting, We may report information about your account to credit bureaus. Late payments, missed payments, or other defauts on your account m be reflected in or credit/ report. We normally, report the status and payment history of your Account to credit reporting agencies each month. If you believe that our repot is inaccurate or incomplete please write , us at the following address: Discover, PO Box 15316. Wilmnglon, DE 19850.5316. Please nMde your name, address, home telephone number and Account number. Grace Period on Purchases (at least 25 days). We begin to impose Periodic Finance Charges on all transactions from live Trahsadw pate for the transaction as shown on you biting statement, unless a transaction is posted to your Account after the dose of the billing period in which it occurs In wh ch i , i case we beg n to impose Periodic Finance Charges on that transaction from the first day of the billing period in which it is posted to your Amount. We continue to impose Periodic Finance Charges until the data you pay your entire New Balance, by m" payments or receiving credits. However, if you paid the New Balance on your previous trillin statement b th P D g y e ayment ue Date shown on that bating statement and you pay tits the on your anent billing sWtdment, we wit no impose Periodic Finance Charges on new prMases, that is. purchases first appearing on the current e New aby the statement We call Payment Due Date th billing grace period.' There is no grace period on balance transfers or cash advances. Minimum Finance Charge. We wig charge you a minimum FINANCE CHARGE of $.50 for any billing period in which Periodic Finance Charges of less than $.50 would otherwise be imposed. Annual Fee. If your Account has an annual fee, it wit be billed at the beginning of each anniversary year your Account is open. The amount of the lee appears on the saement when [lie fee is billed. The annual pee is not refundable unless you richly us that you wish to close your Account within 30 days of the mailing or delivery date of tine statement on which the fee is billed. You will receive this refund even it you use your Card during that period Periodic Finance Chases. We son you transactions into groups ol purchases, cash advances, and balance transfers and then further sot the lransactiohs within each group by theirArnual Percentage Rabe. For example, pudhases subject to a promotional rate and purchases subject to a standard rate would be separate groups. We refer to thesis groups as transaction categories. At the and of each biting period, we compute balances and Periodic Finance Charges for each day of the billing period for each transaction category. We use tug fdlowimg equation to compute Periodic Finance Charges for each transaction category. (Average Daily Balance) times (days in billing period) tines (Daily Periodic Rate). ((Y P for ou may refer to the finance charge summary on your biding statement for these anmounts.l Then we add up the Periodic Finance Charges for each transaction category to get the total Van !f? your Account. The Average Daily Balance is shown as zero rf, because of the grace period, no Periodic Finance Charges apply to the balance in a e the We use for a gD? Balance c(vicluding new by adding up a ansactms) method of calculating the balance upon which we impose Periodic Finance Chharges. We compute the Average Daily the c daily balance for each transaction daily balances in a billing period for a mansadon category and dividing the Iola! by the number of days in the billing period. ? Compute a d category on each day by fast adding the following to the previous day's daily balance: transactions with a Transaction Date of that ay as shown on your billing statement, unless die transaction is posted to you Account after the dose of the biting period in which it scars. in which case the transaction wit be added to the daily balance as of the test day of the billing period in which it is posted to your Accent, fees charged that day and Periodic Finance Charges accrued on the previous day's dairy balance the iiiii; period, we consider a than subtracting credits and payments that are applied against the balance of the transaction category an that day. In calculating the defy balance for the fist day of previous day's daily balance' to have been your balance for each transaction category on the fast day of your previous biting period. All fees charged to your Account are added to the standard purchase transaction category with the exception of Cash Advance Transaction Fee Finance Charges which are added to the applicable cash advance transaction category and Balance Transfer Transaction Fee Finance Charges which are added to the applicable balance transfer transaction category. Wlhen Hwespecial ver. rate the xpires, we move the unpaid balance of tie balance transfer and the Balance Transfer Transaction Fee Finance Charges to the standard purchase barisaAOn category; o special rate has been terminated under the Default Rate section, we leave the unpaid balance of the balance transfer and the Balance Transfer Transaction Fee Finance Charges in the applicable balance transfer transaction category until the special rate would have expired. For TOO (Telecommunications Device for the DeaQ assistance, pease call 1400.347.7449. Discover may monitor andlor record telephone cats between you and Discover representatives for quality assurance puMoses, The Discover' card is issued by Discover Bank. Member FDIC. 01TBKII I 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 Corporation 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# 9089759 Christopher Vanbrederode 6011002481332278 DISCOVER BANK vs Plaintiff IN THE COURT OF COMMON PLEAS OF FILED-OFFICE CUMBERLAND COUNTY, PENNSYLVANIA OF THE PROTHONOTARY CIVIL DIVISION 2011 JUL -8 PM 3: 40 CUMBERLAND COUNTY PENNSYLVANIA Civil Action No. 11-4262-CIVIL CHRISTOPHER VANBREDERODE TO THE PROTHONTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant CHRISTOPHER VANBREDERODE above named, in the default of an Answer, in the amount of $5923.06 computed as follows: Amount claimed in Complaint Less payments / adjustments made Interest on the remaining principal ba $3745.73 from July 31, 2009 to June @ the interest rate of 28.990% per Attorney's fees TOTAL $3745.73 $0.00 Lance of 23, 2011 annum $2052.33 $125.00 $5923.06 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. 0908975 Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsbur h, And that the last known address of the CHRISTOPHER VANBREDERODE 18 W LOCUST ST MECHANICSBURG, PA 17055 warmbrodt,42524 A Pit SJS A 15219 ndant is 'P,"e44,?J 41Y.ov ckd Sag/,TLS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff Case No. 11-4262-CIVIL VS. CHRISTOPHER VANBREDERODE Defendant IMPORTANT NOTICE TO: CHRISTOPHER VANBREDERODE 18 W LOCUST ST MECHANICSBURG, PA 1705?5, Date of Notice: j ft i i YOU ARE IN DEFAULT `BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE, CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA. 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A. 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 9089759 A PIT BS4 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff: vs. Civil Action No. 11-4262-CIVIL CHRISTOPHER VANBREDERODE 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 VANBREDERODE 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 VANBREDERODE 18 W LOCUST ST 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-28-2011 10:51:16 :. Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency VANBREDERODE 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). 14. 44,? f q 4(0j4j,*j_ 4?? Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink.mil/faq/`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.mililappj/scra/popreport.do 6/28/2011 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 repcrted 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:U7CPKTRL75 https://www.dmdc.osd.mil/appj/scra/popreport.do 6/28/2011 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. CHRISTOPHER VANBREDERODE Civil Action No. 11-4262-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 ^y leut T (xx) Assumpsit Judgment in the amount of $5923.06 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 w J'ah- By: PROTHONOTAROR DEPUTY CHRISTOPHER VANBREDERODE 18 W LOCUST ST 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