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Home My WebLink About11-4672t FtL ED-DFFCF vll y-1 PM 12:rG CUMBERLAND COUNTY P1ENN SYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs CHARLES E GOOD Defendant No : 11(17,;Z- ?Itj 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 09133148 C A Pit CXC 61 ?d 9a-ad ?y l?k? s?o0??v 71e'01a04a1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No HARLES E 1,00D 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. CHARLES E GOOD 1017 VALLEY ST ENOLA, PA 17025 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX8631 . 4. Defendant made use of said credit card and has a current balance due of $4742.85 , as of March 31, 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 21.2400 per annum on the unpaid balance from March 31, 2011 . A copy of Plaintiff's Statement is attached hereto, marked as Exhibit I'll' 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. Z-lthough 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 , CHARLES E GOOD individually , in the amount of $4742.85 with interest at the rate of 21.2406 per annum from March 31, 2011 plus attorneys' fees of $125.00 , and costs. Jam s C War ro t,42524 WELTMAN WEINBERG & REIS CO., L.P.A. 436 Se th Avenue, Suite 1400 Pittsb r h, PA 15219 (412) 43 -7955 FAX: 1 -338-7130 0913 14 C A Pit CXC This law firm is a debt collector attem t'ng to collect this debt for our client and any information obtaine ill be used for that purpose. DISC(NER $$00 B-colarce 31 SDSN6A01 0004580 CHARLES GOOD 1017 VALLEY ST ENOLA PA 17025-1339 Go paperless and make your account information more secure with password- protected statements only you can access. Learn more at discover.comfpaperless. PO BOX 6103 111 Mil oil 1111118#1111 loll CAROL STREAM IL 60197-6103 Address, e-maii jr telephone than9e2 ?i?lw?lrrnn???rlnlui?r?lnnrllllnurllr??nnr'In?rrl? o 'o _, .Discover.com or print change in space above. 000001986458571125059000000000000000080000XH1BI? Opening Date: March 21, 2011 - Closing Dabs: March 31, 2011 page 1 of 2 Discover More Card Account Summary Account number ending in 8631 Previous Balance $4,742.85 Payments And Credits 4,742.85 Purchases + 0.00 Balance Transfers + 0.00 Cash Advances + 0.00 Fees Charged + 0.00 Interest Charged + 0.00 - -- New o(ance -50.00 See Interest Charge Calculation section Following transactions for detailed APR information Credit Lme $4,700.00 Credit Llne Available $0.00 Cash Advance Credit line $2,400.00 Cash Advance Credit Line Available $0.00 Cashback Bonuse Anniversary Month May Opening Cashbock Bonus Balance $ 0.00 New Cashback Bonus This Period + 0.00 Cashback Santos Balance $ 0.00 To lam more, log an ar wwwMimover.com Payment Information New Balance $0.00 Minimum Payment Due $800.00 Payment Due Date April 26, 2011 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 26.24% 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 morew-find easy ways to earn and redeem cash rewards • NEW! Access your account securely through your mobile phone 3 Easy Ways to Contact Us 1 Access your account securely at www.Discmer.com 2. Call 1-800-DISCOVER (1-800-347-2683) Please have your Discovers card available. 3. Write to us at Discover, PO Box 30943, Safi Lake City, UT 8,4130 (Not a payment address Far payments, please send to address on remittance or Discover PO Box 6103, Carol Stream, IL 60197-6103 For TDD (Telecommunications Device for the Deaf) assistance, please call 1-800-347.7449 Transactions Trans. Post Dale Date Payments and credits Mar 31 Mar 31 INTERNAL CHARGE-OFF $ -4,742.85 Fees TOTAL FEES FOR THIS PERIOD $ 0.00 kos rest Charged TOTAL BrTEREST FOR THIS PERIOD $ 0,00 2011 Totals Year-to-Dote TOTAL FEES CHARGED IN 2011 TOTAL INTEREST CHARGED IN 2011 9133148 Minimum Payment Due ^: Account Number ending in 8631 $800.00 Enter Amount Enclosed Below Payment Due Date Apra 26, 2011 105.00 156.93 NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION DISC40VEI DISC(NEI It pays to CHARLES GOOD -_DLWAYER- Account number ending in 8631 page 2 of 2 Interest Charge Calculation Your Annual Percentage Rate (APR) is the annual interest rate on your account. Current Blfisg Period: I1 days TYPE OF BALANCE Purchases' 10/ 1012010 and after 10/09/2010 and prior Cash Advances ANNUAL PERCENTAGE BALANCE SUBJECT TO INTEREST RATE INTEREST CHARGE 21.249 V 19.24% V 23.99% V $0 SO $0 $0 $0 $0 V = Variable Rate Dates ooply to non-promotional purchases and to expired promotions with start dates within the specified date range Additional Important Information See your Cordmember Agreanent. Your Cardmember Agreement contains all the terms of your Account. Lost or stolen cords. Report immediately! Cal 1-800-347-2683. What To Do If You Think You Find 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 letter give us the following information: Account information: Your name and account number Dollar amount The dollar amount of the suspected error Descri Hon of P it roblem: If you think there is an error on your bill, describe what you believe is wrong and why you believe is a mists ro. You must contact us within 60 days after the error appeared on your statement. You must notify us of any potential arras in wr itiw tinn You may call us, but if you do we are not required to investigate any potential errors and you may have to pay the amount in question. While we investigate whether or not them has been an error the Following are true: We cannot try to called the amount in question, or report you as delinquent on that amount. The charge in question ma remain on your statement, and we may continue to charge you interest on that amount. But, if we determine that we made ra mistake, you will 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 ff You Are Dissatisfied With Your Credit Card Purchases If you are dissatisfied with the Goods or services that you have purchased with your credit card, and you have fried in good faith to correct the pro lem 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 made in your home 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 mailed to you or if we own the company that sokLyou the goods or services.) 2 You must have used your credit card for the purchase. Purchases made with cash advances from on ATM or with o check that accesses your credit card account do not qualify. 3. You must not yet have Fully paid for the purchase. IF all of the criteria above are met and you are still dissatisfied with the purchase, contact us in write rw at: Discover, PO Box 30945, Salt Lake City, UT 84130-0945 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 t op portnon of this statement in the envelope provided. Do not send cash. By sending your check as described above, authorize us to use information on your check to make an electronic fund fronsfer from your account ot the financiatitution indicated on your check or to process the payment as a check transaction. ff payment is processed os a use nfootin tom your check makelectronic fund hansfer, funds may be withdrawn from your account as soon as the same day we receive your payment, and you will rot receive your check b«k from your financial institution. The pressing of your poymeM may be delayed iF you send cash, corre spondence or other items with your j d tpaent o any oiF u un other n thone providParecivr ocessinfaclity SPM l on any will crted tyour cont as othdayPot infacilty after Sal tiwll ir Accoas of the next dIf yed yr ved r payr x 6103 Card StreIL 60197.6103leasow 7 10 days For delivery . If your payment a returned unpaid, we reserve the rig(nt to resubmit t as an electronic debit. You can pay your scheduled monthly payment or a greater amount that does not exceed your remaining current account balance over the telephone or you can setup automatic payments through a customer service representative by calling 1-800.347-2683. Automatic payments wilt la deducted an the payment due date unless you request o ant date that occurs before your payment due date. If your scheduled payment date falls of a weekend or bank holir oy?your payment will be processed the business day prior to the weekend or bank holiday. In order to schedule monthly payments l? telephone, you will need this statement and your bank account information. You will be asked to provide the lost four (4) r3ignt3 of the social sscur'ty number of the primary borrower By providing those numbers as your electronic signature, you will be agreeing to this authorization to aloes us and your bank to deduct each payment you authorize, in the amount selected by you, from your bank account. You also authorize us to initiate debit or credit entries to your bank account, as applicable, to correct an error in the processing of such payment, You can cancel a scheduled payment by hone at 1-800-347.2683 or l>VkynRiJ7p,? i?gcorrespondence address listed above; however we must receive notice at least three business days in advance dt?sTSdnwuwd payment. If your payments may wry in amount, we will tell you on each manfhly statement when your payment will be made and how much it will be. You must ensure that sufficient funds are available in your bank account, and al transactions must comply with U.S. law. If your scheduled payment is not enough to cover the Total Amount Due as listed on your monthly billing statement, you will be responsible For paying the difference. Your automatic payment amount may be less than the amount indicated on the periodic statement based on credits or payments after the closing date. If you enroll by phone in our automatic payment service, please fill-in the following blanks below and retain the authorization for your records Amount: ? Full Pay ? Min Pay ? Min Pay + 3 Bank Routing 2t: Bank Account Frequency: _ NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION DISCOVER VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsifications to authorities, that she is Natasha Szczvgiel• 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# 9133148 Charles E. Good 6011002452788631 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ??of ?:rr?brr C,FI F r' _-ERIFF 21111 JU' 14 AM 10: 27 `IIJMBERLAHD Pla-*N 5YLVA' J,IA Discover Bank vs. Charles E. Good Case Number 2011-4672 SHERIFF'S RETURN OF SERVICE 06/02/2011 08:10 PM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on June 2, 2011 at 2010 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Charles E. Good, by making known unto himself personally, at 1017 Valley Street, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $43.00 June 03, 2011 RONALD HOOVER, DEPUTY SO ANSWERS, RbNWY- R ANDERSON, SHERIFF ,? t nu ty:,i?tF Sr23f „x011. Irc DISCOVER BANK Plaintiff vs. CHARLES E GOOD TO THE PROTHONTARY: IN THE COURT OF COMMON PLEAS P-I?.. FA-OFFICE ?'?.?? PROTHONOTARY CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION `???8 AM H.3 v' -3ERLANO COUNTY L-NNSYLVANIA Civil Action No. 4672-11 PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant CHARLES E GOOD above named, in the default of an Answer, in the amount of $5157.10 computed as follows: Amount claimed in Complaint Less payments / adjustments made Interest on the remaining principa $4742.85 from March 31, 2011 to @ the interest rate of 21.240% Attorney's fees TOTAL $4742.85 $0.00 1 balance of July 14, 2011 per annum $289.25 $125.00 $5157.10 1 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:? i James C. armbrod TR, 0913314EY CIA Pit SJS Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsbur h PA 15219 And that the last known address of the Vefendant is CHARLES E GOOD 1017 VALLEY ST ENOLA, PA 17025 24 CL64 %) V. Ob f d at? aft-) 66081 r? Rb` a(a pyb WeA-,a wlaa: IN HE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. CHARLES E GOOD Defendant Case No, 4672-11 IMPORTANT NOTICE TO: CHARLES E GOOD 1017 VALLEY ST ENOLA, PA 17025 + Date of Notice: YOU ARE IN DEF?,ULT 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, WEINQZ?G & 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 9133148 A PIT H4N IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs_ Civil Action No. 4672-11 NON-MILITARY AFFIDAVIT CHARLES E GOOD 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 , CHARLES E GOOD 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: CHARLES E GOOD 1017 VALLEY ST ENOLA, PA 17025 Affiant further states that the averments contained herein are true and correct to the best of Aff_iant'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 Jul-19-2011 08:27:43 " Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency GOOD CHARLES 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). Atut fq. 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 .:;nforcement 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 htti)://www.defenselink.mil/fag/pis/PC09SLDR.htrnl. If you have evidence the person is on active duty and ycru 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 Presider: t 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: (AG 11t) members must be assigned against an authorized mobilization position in the unit they support. This includes Davy TARS, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service mernber,:rho is an active duty commissioned officer of the U.S. Public Health Service or the https://www.dmdc.osd.m,'I/'app:,'scra/popreport.do 7/19/2011 Request for Military Sta'us Pa e2of2 g Nationaf Oceanic and Atrnospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCR4 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 web rite 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 t"',-, SCRA are protected. WARNING: This certifi :?,te w ".,.s provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause ar e -<oneous certificate to be provided. Report ID:IM18B4H1 C1.1 https://www.dmdc.osd.m;]/app.i,lscra/popreport.do 7/19/2011 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 4672-11 CHARLES E GOOD 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 $5157.10 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 ( ) Ar_bitrati Aw d Prothonotary By: ?. CHARLES E GOOD 1017 VALLEY ST ENOLA, PA 17025 Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 a? ? . ?+? ? ? b ? ?? t WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-4672 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From CHARLES E. GOOD, 1017 Valley Street, Enola, PA 17025 (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 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 $5,157.10 L.L. $.50 Interest -- $194.13 Atty's Comm % Due Prothy $2.25 Arty Paid $180.50 Other Costs Plaintiff Paid Date: 3/22/12 Bu , rothonot ry (Seal) By: Deputy REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., LPA 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 PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. CHARLES E GOOD Defendant(s) PNC BANK Garnishee(s) No. 4672-11 PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. 447437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 9133148 . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 4672-11 CHARLES E GOOD, 101'7 V611N 3+, b-iDb PA 1170.0 Defendant(s) PNC BANK , 105 Noble Blvd, &VL%1e 14A Garnishee(s) TO THE PROTHONOTARY: obt s PRAECIPE FOR WRIT OF EXECUTION Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: 2. against CHARLES E GOOD , Defendant 3. against PNC BANK... Garnishee 4. Judgment Amount $ .:k. 77 f-,, .s r•.1 l $5,157.10 Less Payments/credits received $ $0.00 Interest $ $194.13 Costs $ SUBTOTAL: $ $5,351.23 Costs (to be added by Prothonotary): $ s O WELTMAN, WEINBERG & REIS CO., L.P.A. aq.00 100 4 3 . w G3F By. w William T. Molczan, Esquire 9.0•60 PA I.D. #47437 j 14 oo a 501001 WELTMAN, WEINBERG & REIS CO., L.P.A. I a s Ig-4 , S? 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 CV 0?1&N 3 P-* 021195 WWR No. 9133148 [k)ri+c? & j-"t.ca0/ 7 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor 'rG PENNSYLVAMA; Discover Bank vs. Charles E. Good Case Number 2011-4672 SHERIFF'S RETURN OF SERVICE 03/28/2012 01:01 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 28, 2012 at 1302 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Charles E. Good, in the hands, possession, or control of the within named garnishee, PNC Bank, 105 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Susan Casale, Financial Sales Consultant, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on March 29, 2012 to Charles E. Good at 1017 Valley Street, Enola, PA 17025. SO ANSWERS, March 29, 2012 RON R ANDERSON, SHERIFF 1 iam Cline, Deputy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DISCOVER BANK CIVIL ACTION NO. 11-4672 Civil Plaintiff VS. ANSWERS TO INTERROGATORIES IN ATTACHMENT CHARLES E. GOOD Defendant and Filed on behalf of PNC Bank, National Association PNC BAND - - Garnishee --Wi Joel B. Gold, Esquire Sr. Counsel for PNC Bank, National Association Pa. I.D. #42090 PNC Bank, National Association Firm #862 One PNC Plaza, 20th Floor 249 Fifth Avenue Pittsburgh, Pennsylvania 15222-2707 (412) 762-2801/6763 (facsimile) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DISCOVER BANK CIVIL ACTION NO. 11-4672 Civil Plaintiff vs. ANSWERS TO INTERROGATORIES IN ATTACHMENT CHARLES E. GOOD Defendant and Filed on behalf of PNC Bank, National Association PNC BANK Garnishee ANSWERS TO INTERROGATORIES IN ATTACHMENT AND NOW, PNC Bank, N.A., the Garnishee (`Bank"), files this response stating as follows: 1-1 a. The Garnishee has an account titled in the name of the defendant Charles E. Good, which receives a "Benefit payment" on which an "Account review" was conducted. The account is not attached because there were no funds in excess of the "Protected amount". 31 CFR §§212.1 et seq. 2. No. 3. No. 4. No. 5. No. 6. See no. 1. 7. See no. 1. 8. No. 9. Objected to as outside the scope of Pa.R.C.P. no. 3144. 10. Objected to as outside the scope of Pa.R.C.P. no. 3144. 11. No. 12. N/A WHEREFORE, PNC Bank does not admit to holding property of, and does not admit to owing a debt to the judgment defendant. Respectfully submitted, PNC BANK, NATIONAL ASSOCIATION Go , Lit/garnishee answers/Good, Charles E. 04302012 VERIFICATION The undersigned hereby verifies that I am an authorized representative of PNC $ank, N.A.; that the statements made in the foregoing Answers to Interro1gatories are true and correct to the best of my knowledge, information and belief and that these statements are made subject to the penalties of 18Pa. C.S. s4904,1, relating to unsworn falsification to authorities. RE: Discover Bank vs Charles E Good DOCKET NO.: 11-8630-Civil Terra DATE-, May 21, 2012 Theresa A Dusch Team Lead, Garnishment Processing Position Lit-233946.1 WELTMAN, WEINBERG & REIS CO., L.P.A. BY: William T. Molczan, Esquire Attorney for Plaintiff(s) I.D. No.47437 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 9133148 DISCOVER BANK CUMBERLAND County Court of Common Pleas = fi vs. -= CHARLES E GOOD, =M c_a ,.? NO. 4672-11 `<>- and PNC BANK Garnishee(s) - rv cr! PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the above matter discontinued and ended as to Garnishee(s), PNC BANK,, only. WELTMAN, WEINBERG & REIS CO., L.P.A. BY 1,•/ /_ William T. olc , Esquire Attorney for Plaintiff 49•5p P13 ATT' Olt /asVaa9a i2it a7to/ 7 3 o SHERIFF'S OFFICE OF CUMBERLAND COUNTY ny R Anderson ~eriff Jody S Smith '" Chief Deputy ~~ ~ ~ ~(}~! - I I'M ~: I Richard W Stewart _ C~MBERLA~~ Cv~f~ solicitor P~ ~Pt S Y OVA N I A Discover Bank I Case Number vs. 2011-4672 Charles E. Good SHERIFF'S RETURN OF SERVICE 03/28/2012 01:01 PM -William Cline, Deputy Sheriff, who being duly sworn according to law, states that on March 28, 2012 at 1302 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the within named defendant, to wit: Charles E. Good, in the hands, possession, or control of the within named garnishee, PNC Bank, 105 Noble Boulevard, Carlisle, Cumberland County, Pennsylvania 17013, by handing to Susan Casale, Financial Sales Consultant, personally three copies of interrogatories together with three true and attested copies of the writ of execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on March 29, 2012 to Charles E. Good at 1017 Valley Street, Enola, PA 17025. 10/29/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $87.92 SO ANSWERS, ~~~~_ October 29, 2012 RON R ANDERSON, SHERIFF ~. bpd (to . . S~ LL~d - ~~ ~ ~i