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HomeMy WebLinkAbout11-49544 FILED-OFFICE THE PROTHONOTARY ZuII UN 15 PM 2:00 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs NATHAN P ROSS PROGRESSIVE PROPERTY GROUP No: ''^Ov I by?) COMPLAINT IN CIVIL ACTION Defendants 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 08792669 C A Pit KMJ CD Gig. co p+ a aM? I?_ CL it Sa i 104 q i;k pit ac0osyo IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No NATHAN P ROSS PROGRESSIVE PROPERTY GROUP Defendants 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. Defendants are adult individual(s) residing at the address listed below: NATHAN P ROSS 813 OLD SILVER SPRING RD MECHANICSBURG, PA 17055 PROGRESSIVE PROPERTY GROUP 1303 CHERRINGTON DR HARRISBURG, PA 17110 3. Defendants applied for and received a credit card bearing the account number XXXXXXXXXXXX4813 4. Defendants made use of said credit card and has a current balance due of $5264.61 , as of September 30, 2010 . 5. Defendants are 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 29.990% per annum on the unpaid balance from September 30, 2010 . A copy of Plaintiff's Statement is attached hereto, marked as Exhibit "1" and made a part hereof. 7. Plaintiff avers that the Agreement between the parties provides that Defendants will pay Plaintiff's attorneys' fees. 8. Plaintiff avers that such attorneys' fees will amount to $125.00 9_ Although repeatedly requested to do sc by Plaintiff, Defendants have willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for Judgment in its favor and against Defendants , NATHAN P ROSS AND PROGRESSIVE PROPERTY GROUP ,jointly and severally , in the amount of $5264.61 with interest at the rate of 29.990% per annum from September 30, 2010 plus attorneys' fees of $125.00 , and costs. James WELTM 436 S Pitts (412) FAX: 08792 This law firm is a debt collector attempt our client and any information obtained W warmbroau,42524 WEINBERG & REIS CO., L.P.A. .th Avenue, Suite 1400 h, PA 15219 -7955 338-7130 C A Pit KMJ to collect this debt for be used for that purpose. DISCOVER 55Z?bnce • 22 SDSN6AOt 0009655 ROSS, NATHAN P PROGRESSIVE PROPERTY 1303 CHERRINGTON DR HARRISBURG PA 17110-9497 Minimum Payment Due Account Number ending in 4813 51,644.00 Enter Amount Enclosed Below Payment Due Date $ April 12, 2011 For access to the easiest online account management options that put you in control of your account, register at Discoverbiz.com/register PO BOX 6103 111rrr11rrrs 1111111s1s11rs1 Address, CAROL STREAM IL 60197-6103 , r g*-mail or o to Di bo com?nt Print your e-mail spas above il address to receive important Account information and special offers. 000001986751572147407052646100300000164400 Discover Business Miles Card Account Summary Closing Date: March 22, 2011 page 1 of 1 Account number ending in 4813 Previous Balance $5,564.61 Payment Due Date April 12, 2011 Payments And Credits 300.00 Minimum Payment Due $1,644.00 Purchases + 0.00 Credit limit $4,800 Cash Advances + 0.00 Credit Available s0 Balance Transfers + 0.00 Cash Credit limit $1,200.00 Fiance Charges + 0.00 Cash Credit Available $0.00 New Balance a $5,264.61 Miles Summa Open' Miles Balance 0 ry New M Earned + 0 Mims Balance 0 Miles Anniversary Date: May 22 How Can We Help You? For Amount Inquries, write to us at: Discover Business Card, PO Box 3023 Please have your Diseowr Card available. New Albany, OH 43054.3023 Menage year amount online at D scowrbu corn TDD (Telecomrimicatiens Device for the Deal): Customer Service: 1-888-DISCOVER (1-888-347-2683) For assistance, see reverse side. PROGRESSIVE PROPERTY Activity on Account Trarm Post Dale Data Payments mid Credits Feb 28 Feb 28 PAYMENT THANK YOU $ .300.00 EXHIBIT fg4gW@qCharge Summary Da t o Nominal AN NUAL A Perio dic Transaction ily dic P PB GE FINANCE FIMAtJCE 8 nc Rates RATES RATES CHARGES CHARGES current billing period: 28 days Purchases 0 t 0.08216% 29.99% V 29.99% 0 $0 PurchaseChecks 0 0.08216% 29.99% V 29.99% 0 t SO Cash Advances $0 0.08216% 29.99% V 29.99% o 0 The rates that apply to your Account are either fixed IF) or they may vary IV) 03 noted above w Important Information. It there is more than one page b this billing statement, see the back of each page for additional kmportat information. Sea your Cardmember AWmmnL Yaw Cardmember Agreement contains all the tams of your Amount Lost or siden arm. Report i mediatdy! Call /2M3g4693. Paymsnb. Send only your payment and the tap portion of this state mteni in the envelops provided. Do not send ash. By sending your check as described above. you aAOM 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 proem the payrrort as a dhedk bans don. t payment is processed as an electronic kind transfer, the Vans* will be for the ertount of the check. When we use i formation from your check to `mak?e an electronic find transfer. funds may be withdrawn from your account as soon as the same day we receive your paymeril and you will not receive your check back from your I WXW kmdkrodn. The processing of you payment may be delayed If you send cash, correspondence or other items with your fxynent, t you send the payment to any otter address or f you use an envelope other than the one provided. Payments received in paper form at our processing facility by 5Wd local time on any day will be cre I , to your Account as of tat day. Payments received at our processkg facility alter 5PM ncal time will be credited b your Account as of the next day. t you have misplaced your envelope, sand your payment No Discover, PO Box 6103, Card Streem, IL 60197.6103. Plem allow 1-10 days for delivery If your payment is retuned unpaid, we reserve tte right to resubmit it as an elecbortlo debt. You an pay your minimum payment or a greater amount over the telephone and you an set up automatic payments. Call us at 188&347-2663. You will need lids statement and your bank account mormatm. You must ensure ttat suficient ludo are available in your bank account and at rransactots rust comply wth US law. You will be asked to provide the fret 5 digta of your accord statement ZIP code. By entering these numbers as your electronic signahne, you wit be agreeing to he auAhmQaton to slow us and your bank to deduct each paynhent you autiorae from you bards account and to initiate debit orcredit entries to your bank account, as applicable, b correct an ems in the paoessirg of such paymenh. You must tag us the am ot" of each payment, or you can select an amount such as the MfimirmlYn Payment Due or the New Balance on each statement You can arced a payment; however, we must receive notice at least tree business days in advance of the scheduled ,?pra,?y'ment You may notify us by phone at 1?6t8.347-2683 or by mail at the address fisted n to previous paragraph. It you payments may vary in amant we will tell you on each montty statement when your payment will be made and how much it will be. You alfmhade payment amount may be less than instated on the monthly statement based on credits or payments applied during On baling cycle. Credit Reporting. Vie may report kllomnatia about your account to asdir bureaus. Late payments, missed payments, or other defaults on you account may be reflected in you credit report. It you believe tut our repot is inaccurate or incomplete, pease wile us at the kdbwing address: Discover, PO Box 15316, Wikni glm, DE 19850-5316. Please include your name, address, hone telephone number and Account number. Periodic Fiume Charges. We begs to impose Periodic Finance Charges on at transactors from the Transacion Date for me tranuctim as shown on your bRnhg statement, unless a transaction is posted to yarAccoW after the dose of is billing period in which t occurs, in which case we begin to moose Periodic Finance Charges on that transaction from the fast day of the billing period in which it is posted to your Accent We continue to impose Periodic Frhatce Charges unit dw date you pay your entire New Balance, by making payments or receiving credits However, t you paid the New Balance on you previous billing statement by tie Payment Due Dab shown on that bang slatemwnt and you pay the New Balance by the Payment Due Deb on your current billing stalenhent, we will not irrnp0ae Periodic Fklamha Charges on new Purchases, that is, purchases fret appearing on the arrent biting statement. We cat On the `grace period.' There is no grace period an balance transfers, ash advances, or PudaseC leeks. We sort your transactions into grow" of purchases, ash advances, and balance transfers and then further sat the transactions wittkh each group by their Air" Percentage Raw. For example, purchases subject to a promotional rate and purchases subject to a standard rate would be separa a groups. WB refer to these groups as bai saclim cabgaies. At the end of each biting period, we mwlpute balances and Periodic Finance Charges for each day of tine biting period for each transaction category. We use the following equation to conpde Periodic Finance Charges or each trasactm category, (Average Daily Balance) Nat (days in bitting period) times (Daily Periodic Rate). (You may refer to the friahoe charge summary on your billing statemwnt for these amounts.) Then we add up the Palo* Finance Charges for each transaction cam" to get the total Periodic Finance Charges for yorAmount. The Average Daily Balance is shown as zero if. because of the gram period, no Periodic Frhance Changes apply to the balance In a transaction category. We use the Average Daly Balance (including new transactions) mettod at c*Uakrg the balance upon which we klpm periodic Finance Charges. We arlpl/l! the Average Daily Balance for each transaction category by adding up all the daily balances in a billing period or a transsactim category and dividing this owl by the number of days in the befrg period. We compute the defy balance for each transaction category on each day by first adding the otowkg to the previous day's daily balance: transactions with a Transaction Dale of that day as shown on your biting statement, mless the transaction is posted to your Account after the dose of the bating period in which t scar^s?, n.,,wi,.h.ch case the O enheactlon wt, be added to in daily balance as of the first day of the bhg period in w4tch 4 is posted to your Amount, lea charged that day and Periodic Fnence Charges ao=W on lib peviose day's defy balaincit; the billing ppeerioby than sulittacting d, we consider tlhe?prevcredits and payments 'iois day's daily balance to have baaliahce for balance adhtratransaction category nssac an that say in c*W*V the previous daily balance for the that day of bgdny on the last day of your bYlYg period. At tees charged to your Account are added to do standard pumhm transaction category will the atimptm of Cash Advance Transaction Fee Finance Cho" Mich are added to to applicable cash advance transaction category and Balance Tramwr Transaction Fee Finance Charges which we added to the applicable balance carder to si d art cawgory W ein lib medal rate expires, we move ds unpaid balance of the balance transfer and the Balance Transfer Transaction Fee Finance Chagas b the standard card Within banaad8m category . However. if the 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 trallelBt transaction category until the special raw would have expired. For TDD (Tewcommtmicatms Devike for the DuQ esalatana, platy all 1d1pg.347.7449. Discover may monlix and/or record bkplhone calls behveen you and Discover representatives for quality assurance purposes. The Discover card is issued by Discover Bank, Member FDIC. 8792669 OITBK191 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 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. 1 ? ? p (ignature) WWR# 8792669 Nathan P. Ross 6011398591554813 SHERIFF'S OFFICE OF CUMBERLAND FeQM1 jjF?(CF Ronny R Anderson rid- THE PROTHONGJ si`c' Sheriff 2011 JUL 15 AM 8: 53 Jody S Smith Chief Deputy CUMBERLAND COUNTY Richard W Stewart PENNSYLVANIA Solicitor `R"r Discover Bank vs. Nathan P. Ross (et al.) Case Number 2011-4954 SHERIFF'S RETURN OF SERVICE 07/12/2011 05:00 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on July 12, 2011 at 1700 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Nathan P. Ross, by making known unto a female homeowner also known as the Defendant's Wife, at 13 Lismore Place, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $48.44 July 13, 2011 a TIM BLACK, DEPUTY SO ANSWERS, ROW R ANDERSON, SHERIFF . ?ounfySuttc-e-e Shen'f. Tele?sof(. Inc. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs NATHAN P ROSS PROGRESSIVE PROPERTY GROUP `i COUNT NI Civil Action No. 11-4954-CIVIL PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONTARY: Kindly enter Judgment against the Defendants NATHAN P ROSS , PROGRESSIVE PROPERTY GROUP , above named, in the default of an Answer, in the amount of $6777.95 computed as follows: Amount claimed in Complaint $5264.61 Less payments / adjustments made $0.00 Interest on the remaining principal balance from September 30, 2010 to August 25, 2011 @ the interest rate of 29.990% per annum $1388.34 Attorney's fees $125.00 TOTAL $6777.95 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: Jam Pd C??- l o?ooaig y ?? a L451o s V?,ln C'k Ocu (ea 08792669 C A Pit SJS Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 And that the last known address of the Defendants are NATHAN P ROSS 13 LISMORE PL MECHANICSBURG, PA 17050 PROGRESSIVE PROPERTY GROUP 1303 CHERRINGTON DR HARRISBURG, PA 17110 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff Case No. 11-4954-CIVIL vs. PROGRESSIVE PROPERTY GROUP NATHAN P ROSS Defendant IMPORTANT NOTICE TO: NATHAN P ROSS 13 LISMORE PL MECHANICSBURG, PE, 17050 Date of Notice: ?q YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE !N 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 OFF CE SET FORTH BELOW. THIS OFFICE CAN PROVIDE'. OU 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 TWN T MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA. 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A By: Matthew Urban PA 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 8792669 A PIT M4Z IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. NATHAN P ROSS PROGRESSIVE PROPERTY GROUP Civil Action No. 11-4954-CIVIL NON-MILITARY AFFIDAVIT The undersigned is the duly authorized agent and/or attorney for the Plaintiff in the within matter and states as follows: Affiant states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendants , NATHAN P ROSS , PROGRESSIVE PROPERTY GROUP , are 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: NATHAN P ROSS 13 LISMORE PL MECHANICSBURG, PA 17050 PROGRESSIVE PROPERTY GROUP 1303 CHERRINGTON DR HARRISBURG, PA 17110 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 Sep-02-2011 08:45:48 -. Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency ROSS NATHAN 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). AMY, Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd, Suite 400 Arlington, VA 2:'209-2593 fhe Defense: Mancx)wer 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 1ittn://xNwrw.defenseIink.mil/faq/pis/PC09SI DR html. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SC'RA 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. https://www.dmdc.osd.mil/appj/scra/popreport.do 9/2/2011 'Request for Military Status Page 2 of 2 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 National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who woula 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:RU33HE24T4 https://www.dmdc.osd.inil/appj/scraJpopreport.do 9/2/2011 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK vs Plaintiff Civil Action No. 11-4954-C7-VIL NATHAN P ROSS PROGRESSIVE PROPERTY GROUP NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the f llowing Order of Judgment was entered against you on (xx) Assumpsit Judgment in the amount of $6777.95 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 ( ) Arbitratiol% Prothonotary By: NATHAN P ROSS 13 LISMORE PL MECHANICSBURG, PA 17050 PROGRESSIVE PROPERTY GROUP 1303 CHERRINGTON DR HARRISBURG, PA 17110 Plaintiff's address is: C/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. No. 11-4954-CIVIL PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) NATHAN P ROSS PROGRESSIVE PROPERTY GROUP Defendant(s) METRO BANK M&TBANK Garnishee(s) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 8792669 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff PL. Vfl 00 vs. (0 Civil Action No. 11-4954-CIVIL ?e - lb NATHAN P ROSS u PA PROGRESSIVE PROPERTY GROUP - 13o3 'C 6rrins+on Dr, I W-6sb^9 11110 c-) C } Defendant(s) -vim N z? s METRO BANK - do Noble Blvd O&rlisle PA 1`1013 ern ss rn i= =? M & T BANK-1 W. N1gh5t,(?q,rt, PA t?ot3 p c)I Garnishee(s) PRAECIPE FOR WRIT OF EXECUTION c) _ TO THE PROTHONOTARY: -- CO Kindly issue a Writ of Execution in the above matter... I . directed to the Sheriff of CUMBERLAND County: ?0+ X07. 3? 2. against NATHAN P ROSS PROGRESSIVE PROPERTY PROGRE; 4 '7U. J9 3. against METRO BANK, M & T BANK,, Garnishee 4. Judgment Amount $ $6,777.95 Less Payments/credits received $ $507.36 Interest $ $128.45 Costs $ SUBTOTAL: $ $6,399.04 Costs (to be added by Prothonotary): s #aa.oo PA AV-4 X16.44 CBF 99.00 14. o0 a 50 ,? #1195.44 -Pp ATr/ 4,2-as buedo •5o LL 0'tl0a9&tq(* P'# a tog 5&9 WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. Molczan, uire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR No. 8792669 U)ri+a,? roc J"wd WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-4954 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From NATHAN P. ROSS, 13 Lismore PL, Mechanicsburg, PA 17050 PROGRESSIVE PROPERTY GROUP, 1303 Cherrington Dr, Harrisburg, PA 17110 (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: M&T BANK, I West High Street, Carlisle, PA 17013 METRO BANK, 20 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 $6,270.59 Interest -- $128.45 Atty's Comm % Atty Paid $185.94 Plaintiff Paid Date: 1/10/12 L.L. $.50 Due Prothy $2.25 Other Costs (Seal) 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 WELTMAN, WEINBERG & REIS CO., L.P.A. BY: James C Warmbrodt, Esquire I.D. No.42524 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 8792669 FI'LED -OF I'iCE 07 THE PROTHONOAAW Attorney for P1aiWEB -3 AM 11: 50 CUMBERLAND COUNT`` PENNSYLVANIA DISCOVER BANK vs. Cumberland County Court of Common Pleas NATHAN P ROSS PROGRESSIVE PROPERTY GROUP NO. 11-4954-CIVIL and METRO BANK AND M&T BANK Garnishee(s) PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter discontinued and ended as to Garnishee(s), METRO BANK AND M&T BANK, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By Sworn to and subscribed Before me tot 2 3 day?f January, 2012 James CTarmbrodt, Esquire Attorney /for Plaintiff / Notarial Seal . Jy Gault, Notarp Pi bk NOT RY PUBLIC i ? iL 4, A rishurgh, Allegheny County I_ r ri z on Expires July 15, 2014 Mormi,ir. Pcnnzvlv&nia Asgodation of idc rips ' Qawe 9-sop d Ck? ao3au?? ?` 10 V4 U7(0.