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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
ALBERT R WILSON JR
Defendant
No : ) ? r 7 ? 0-1) b 1
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
09196695 C A Pit SJS
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No
ALBERT R WILSON JR
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:
ALBERT R WILSON JR
656 BURNT HOUSE RD
CARLISLE, PA 17015
3. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXX3487 .
4. Defendant made use of said credit card and has a current balance
due of $13069.47 , as of April 30, 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
20.240% per annum on the unpaid balance from April 30, 2011 . 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 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 , ALBERT R WILSON JR INDIVIDUALLY , in the amount
of $13069.47 with interest at the rate of 20.240% per annum from April
30, 2011 plus attorneys' fees of $125.00 , and costs.
James C` a ro t,42524
WELT= EINBERG & REIS CO., L.P.A.
436 Se en Avenue, Suite 1400
Pittsb rg PA 15219
(412) 434 7955
FAX: 12 38-7130
0919 69 C A Pit SJS
This law firm is a debt collector attem ng to collect this debt for
our client and any information obtained ill be used for that purpose.
DISCOVER Now Balance Minimum Payment Due Account Number ending in 3487
$2,248.00 Enter Amount Enclosed Below
Payment Due Date
May 25, 2011
29 SDSN6A010006474
ALBERT WILSON JR
656 BURNT HOUSE RD
CARLISLE PA 17015-9123
Go paperless and make your account
information more secure with password-
Protected statements only you can access.
Learn more at discovercorrdpaperless.
PO BOX 6103 111 111111 11111111111111411111511
CAROL STREAM IL 60197-6103
Address e-mail or telephonechonge2 l?ii??llnunlll?lnlu?l?llnnBill] i1nilltilin111lt41r1ll
Go to www.Discovw.com or print change in space above.
000001486458616723884000000000000000224800
Opening Date: April 12, 2011 - Dosing Date: April 29, 2011
Discover More Card Account Summary
Account number ending in 3487
Previous Balance $13,069.47
Payments And Credits 13,069.47
Purchases + 0.00
Balance Transfers + 0.00
Cash Advances + 0.00
Fees Charged + 0.00
Interest Charged + 0.00
New Balance $0.00
See Interest Charge Calculation section following
transactions for detailed APR information
Credit Line $11,800.00
Credit Line Available $0.00
Cash Advance Credit Line $3,300.00
Cash Advance Credit Line Available $0.00
EXHIBIT
page 1 of 2
Payment Information
New Balance $0.00
Minimum Payment Due $2,248.00
Payment Due Date May 25, 2011
Late Payment Warning: If we dc 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 25.24% 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 moreSM -find easy ways to earn
and redeem cash rewards
• NEW! Access your account securely through your
mobile phone
3 Easy Ways to Contact Us
Cashback Bonuse Anniversary Month 1 Access your account securely at www.Discovw.com
2. Call 1-800-DISCOVER 11-800-347-2683)
July Please have your Discover& card available.
Opening Cashback Bonus Balance S 0.00 3, Write to us at Discover, PO Box 30943,
New Cashbock Bonus This Period + Soh Lake City, UT 84130 (Not a payment address)
0.00 For payments, please send to address on remittance or
Cashback Borers balance $ 0.00 Discover, PO Box 6103, Carol Stream, IL 60197-6103
To leam more, log in w www.Discover.com For TDD (Telecommunications Device for the Deal)
assistance, please call 1-800-347-7449
Transactions
Trans. Post
Dare Date
Payments and Credits Apr 30 Apr 30 INTERNAL CHARGE-OFF
S 13,069A7
Fees TOTAL FEES FOR THIS PERIOD S 0.00
Interest Charged TOTAL W4MST FOR THIS PERIOD $ 0.00
2011 Totals Year-to-Date
TOTAL FEES CHARGED IN 2011
TOTAL INTEREST CHARGED IN 2011
9196695
S 140.00
641 .39
NOTICE SEE REVERSE SIDE FOR IMPORTANT INFORMATION DISCOVER
DISCOVER
It Pars to ALBERT WILSON JR
Account number ending in 3487
DISC _=VEW
page 2 of 2
Interest Charge Calculation
Your Annual Percentage Rate (APR) is the annual interest rate on your account.
Curnsid Billing Period: 18 days
TYPE OF BALANCE
Purchases'
11/01/2010 and chor
10/31 /201 o and prior
Cash Advances
ANNUAL PERCENTAGE
RATE (APR(
BALANCE SUBJECT TO
INTEREST RATE
INTEREST CHARGE
20.24% V
15.24% V
22.99%
$0
$0
$0
$o
$0
$0
V = Variable Rate
Dates apply to non-promotional purchases and to expired promotions with start dates within the specified date range
Additional Important Information
See your Cordmember Agreement. Your Cardmember Agreement contains all the terms of your Account.
Lost or stolen cards. Report immediately! Call 1-800.347-2683.
What To Do if You Think You Find A Mistake On Your Statement
If you think there is an error on your statement, write to us at: Discover PO Box 30421 Sob Lake City, UT 84 1 30-042 1
In your letter, give us the following information:
Account information: Your name and account number
Dollar amount: The dollar amount of the suspected error.
Deisscriamiststion o cef. Problem: If you think there is an error on your bill, describe what you believe is wrong and why you believe
it
You must contact us within 60 days after the error appeared on your statement.
You must notify us of any potential errors in writing. 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 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 questi:% may remain on your statement, and we may continue to charge you interest on that amount. But if
we determine that wade a 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 Riahts if 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 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 right, all of the following must be true-
I 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 sold you the goods or services.)
2 You must have used your credit card for the purchase. Purchases made with cash advances from an ATM or with a
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 writing at-
Discover , PO Box 30945, Solt 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 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 on electronic fund
transfer ham YYour account of the financial institution indicated on your check or to process the payment as a check
transaction. It payment is processed as an electronic fund transfer, 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 from your account as soon as
the some day we receive your payment, and you will not receive your check back from your financial institution.
The processing of your payment may be delayed iF you send cash, correspondence or other items with your payment, if you
send the payment to any other address or if you use on envelope other than the one provided. Payments received in proper
form at our processing Facility by SPM lace! time on any d wiN be credited ro your Account as of that dy. Payments
received at our processmg fanhty aker 5PM local time will credited to r Account as of the next da ay. If you have
misplaced your envelope, send your payment to Discover PO Box 6103 Carol Stream, Ill 601 97 6 1 03. Please allow 710
days for delivery . If your payment is returned unpaid, we reserve the rig?it to resubmit it 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 will be deducted on the payment due date unless you request a ppaayment date that
occurs before your payment due dote. IF your scheduled payment date FoNs on a weekend or bank holiday, your payment will
be processed the business day prior to the weekend or bank holiday. In order to schedule monthly payments by telephone,
you will need this statement and your bank account information. You will be asked to provide the last four (4) digits of the
social security number of the primary borrower By providing those numbers as your electronic signature, you will be
agreeing to this authorization to allow 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 a licable, to
correct an error in the processing of such payment. You can cancel a scheduled payment by phone at 1-800-347-2683 or
b mail at the correspondence address listed above; however we must receive notice at least three business days m advance
VRAM payment. If your payments may vary in amount, we will tell you on each moMr statement when your
made and how much it will be. You must ensure that sufficient funds are ovailoble in your bank account, and
all transactions must comply with U.S. Taw. 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 + $
Bank Routing #:
Bank Account
Frequency:
NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION DISCOVER
i
Paperless statements mean less clutter, more convenience
Easily access up to 24 months of downloodable, password protected statements.
• See your statement as soon as it's available rather than wait for it to arrive in your mailbox.
• Get helpful payment reminders through e-mail or text messages on your mobile phone.
• Print a paper copy of your statement anytime.
• Sign up today at Discover_com/paperless
@2610 Di,- Back, Member FDIC PAPER.0310
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9196695
Questions? Visit www.Discover.com or
call 1 -800-DISCOVER (1-800-347-2683) 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 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# 9196695
Albert R. Wilson
6011002581293487
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith c 4 7,? i l`CJ ,; `F
Chief Deputy '?1I AUG _8 PM
Richard W Stewart
solicitor -UMBERLM-ID CUU -I
PEN SYU,1AMIA
Discover Bank
vs. Case Number
Albert R. Wilson, Jr. 2011-5775
SHERIFF'S RETURN OF SERVICE
07/28/2011 08:52 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on July 28
2011 at 2052 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Albert R. Wilson Jr., by making known unto himself personally, at 656 Burnthouse Road,
Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him
personally the said true and correct copy of the same.
G TSHA UTY
SHERIFF COST: $34.00
August 02, 2011
SO ANSWERS,
RON R ANDERSON, SHERIFF
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 11-5775 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s)
From ALBERT R. WILSON, JR., 656 BURNT HOUSE ROAD, CARLISLE, PA 17015
(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:
MEMBERS 1sT FCU, 1711 SPRING ROAD, 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 $14,141.99
L.L.$.50
Interest $392.88
Atty's Comm %
Atty Paid $171.50
Plaintiff Paid
Due Prothy $2.25
Other Costs
Date: March 27, 2012
(Seal)
REQUESTING PARTY:
Name WILLIAM T. MOLCZAN, ESQUIRE
David D. Buell, Prothonotary
By:
Deputy
Address: WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 KOPPERS BUILDING
436 SEVENTH AVENUE
PITTSBURGH, PA 15219
Attorney for: PLAINTIFF
Telephone: 412-434-7955
Supreme Court ID No. 47437
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No. 11-5775 CIVIL
ALBERT R WILSON JR V511?t ?(,trnf ? i nix lF, (p?'?ZDIs
Defendant(s) nn /?
MEMBERS I ST FCU 1,11 -?n `f-Pa a, lJ? l? S?? P J4 Garnishee(s)
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Kindly issue a Writ of Execution in the above matter...
1. directed to the Sheriff of CUMBERLAND County:
2. against ALBERT R WILSONJR , Defendant
3. against MEMBERS 1 ST FCU,, , Garnishee
4. Judgment Amount
Less Payments/credits received
Interest
Costs
SUBTOTAL:
Costs (to be added by Prothonotary):
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VA.60 Lt L,(
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$14,141.99
$0.00
$392.88
$14,534.87
WELTMAN, WEINBERG & REIS CO., L.P.A.
By: (?? ?/?
William T. Molczan, Esquire/J
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
saaS tom. ??e.
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p? a73o0?
WWR No. 9196695
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS.
ALBERT R WILSON JR
Defendant(s)
MEMBERS 1 ST FCU
Garnishee(s)
No. 11-5775 CIVIL
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. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR No. 9196695
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff m -Z
Jody S Smith rra r
Chief Deputy =
Richard W Stewart
Solicitor
Discover Bank
Case Number
vs.
Albert R. Wilson, Jr. 2011-5775
SHERIFF'S RETURN OF SERVICE
03/29/2012 10:31 AM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on March
29, 2012 at 1030 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and
monies of the within named defendant, to wit: Albert R. Wilson, Jr., in the hands, possession, or control of
the within named garnishee, Members 1st Federal Credit Union, 1711 Spring Road, Carlisle, Cumberland
County, Pennsylvania 17013, by handing to Paula Breitenbach, Customer Service Representative,
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 30, 2012 to Albert R. Wilson, Jr., at 656
Burnt House Road, Carlisle, PA 17015.
SO ANSWERS,
March 30, 2012 RON R ANDERSON, SHERIFF
Stephen Bender, Deputy
r r
P"1 2: ? t
`s' !J ERL;;ND C0UFdT"
IN THE COURT OF C?t AtIZAPF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
ALBERT R WILSON JR
Defendant
MEMBERS 1 ST FCU
Garnishee
No. 11-5775 CIVIL
PRAECIPE FOR JUDGMENT AGAINST
GARNISHEE
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
Matthew D. Urban, Esquire
PA I.D.#90963
Weltman, Weinberg & Reis Co., L.P.A.
1400 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#9196695
an?? ? I c? .s??d
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IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No. 11-5775 CIVIL
ALBERT R WILSON JR
Defendant:
MEMBERS 1ST 1, CU
Garnishee
PRAECIPE FOR JUDGMENT AGAINST GARNISHEE
TO THE PROTHONOTARY:
Kindly enter Judgment against the Garnishee, MEMBERS 1 ST FCU, in the amount of $2,083.81, which is
less than the amount Defendant owes to Plaintiff and which amount Garnishee has admitted owing to the Defendant,
in answers to Interrogatories.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
Matthew D. Urban, Esquire
PA I.D.#90963
Weltman, Weinberg & Reis Co., L.P.A.
1400 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#9196695
I hereby certify that the address of the Plaintiff is:
c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7'?' Avenue, Pittsburgh, PA 15219
And that the last known address of the Garnishee is: 5000 Louise Drive, P.O. Box 40, Mechanicsburg, PA 17055
IN(I
MEMBERS 1St
FEDERAL CREDIT UNION
March 30, 2012
William T Molczan, Esq.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, Pa 15219
RE: Writ of Execution for Albert R Wilson, Jr
Dear Mr.Molczan:
A search of our records has revealed one (1) checking account and one (1) savings account
bearing the name Albert R Wilson Jr with an address 656 Burnt House Rd, Carlisle Pa 17015.
The checking account reflects an available balance of 2044.49 The savings account reflects a
zero or less balance. Pursuant to the writ, all funds in the aforementioned accounts have been
frozen. The accounts have been restricted from any withdrawal transactions.
Pursuant to Rule 3111.1 of Title 231 as promulgated and made effective on April 1, 2007, the
total balance of both accounts exceeds the general monetary exemption under 42 Pa. C.S. § 8123
and therefore are attachable. The full amount of the attachable funds is contained in the
interrogatories as filed with the Cumberland County Prothonotary.
Since the funds contained in these accounts are attachable, and the account has been restricted
from any withdrawal transactions, any deposits will be held for attachment until the amount
above is satisfied.
Should you have any questions or need any additional information, feel free to contact me at
(800) 283-2328, ext. 5125.
Sincerely,
Christina Bender
Deposit Operations Analyst
Rev: 06/11
4f?6w
5000 Louise Drive • P.O. Box 40 • Mechanicsburg, Pennsylvania 17055 • (800) 283-2328 • www.rnemberslst.org
MEMBERS V
FEDERAL CREDIT UNION
March 30, 2012
Albert R Wilson
656 Burnt House Rd
Carlisle Pa 17015
Total Writ of Execution: $14,141.99
COUNTY Cumberland Docket Number: 11-2029
Account Number: XXX415-0000
Name on Account: Albert R Wilson
Savings: 44.32
-5.00 (Membership Fee)
39.32
Account Number: XXX415-0011
Name on Account: Albert R Wilson
Checking: 2394.49
-50.00 (Processing Fee)
2344.49
$300.00 Statutory Exemption was not taken out.
Christina Bender
Deposit Operations Analyst
Rev: 06111
5000 Louise Drive • P.O. Box 40 • Mechanicsburg, Pennsylvania 17055 • (800) 283-2328 • wwwrnemberslst.org
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No. 11-5775 CIVIL
ALBERT R WILSON JR
Defendant.
MEMBERS 1 ST 1, CU
Garnishee
MEMBERS I ST FCU
5000 LOUISE DRIVE
P.O. BOX 40
MECHANICSBURG, PA 17055
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
( ) Defendant
(xx) Garnishee
You are hereby notified that the
following Order or Judgment as
entered against you on
(xx) Assumpsit Judgment in the amount
of $2,083.81 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
( ) Default
( ) Verdict
( ) Arbitration
Award
Prothonotary
By:
PRO OTARY (OR DEPUTY)
WELTMAN, WEINBERG & REIS CO., L.P.A.
BY: Matthew D. Urban, Esquire
I.D. No.90963
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
Phone: 412.434.7955
Fax: 412.434.7959
File # 9196695
DISCOVER BANK
vs.
ALBERT R WILSON, JR
and
MEMBERS 1 ST FCU
Garnishee(s)
Attorney for Plaiint#ff?s)
t
'UP;IP31 E-R'LA11 40 CCUI-IT,_,
-' Efhi fI S I-'I1r' N 1A
CUMBERLAND County
Court of Common Pleas
NO. 11-5775 CIVIL
PRAECIPE TO SATISFY ATTACHMENT EXECUTION
TO THE PROTHONOTARY:
Kindly mark the above matter satisfied as to Garnishee(s), MEMBERS 1 ST FCU, , only.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By
Matthew D. Urban, Esquire
Attorney for Plaintiff
awl c). SDpA
%pSI'l 3Wb
?-? a-1SLf ? l
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 11-5775 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION - LAW
TO T14E SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s)
From ALBERT R. WILSON, JR., 656 BURNT HOUSE ROAD, CARLISLE, PA 17015
(I )Yqu are directed to levy upon the property of the defendant (s)and to sell
(2) *ou are also directed to attach the property of the defendant(s) not levied upon in the possession
of
GAR] ISHEE(S) as follows:
MErV BERS 1sT FCU, 1711 SPRING ROAD, CARLISLE, PA 17015
and t 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 an?,one other than a named garnishee, you are directed to notify him/her that he/she has been added as a
garni hee and is enjoined as above stated.
Amount Due$12,058.18 L.L. $
Interel st $739.87
Atty'? Comm % Due Prothy $2.25
Atty )paid $224.00 Other Costs
PlaiOff Paid
Date: SEPTEMBER 4, 2012
(Sea])
REQUESTING PARTY:
Name : WILLIAM T. MOLCZAN, ESQUIRE
Addr¢ss: WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 KOPPERS BUILDING
436 SEVENTH AVENUE
PITTSBURGH, PA 15219
Attorney for: PLAINTIFF
Telephone: 412-434-7955
Suprome Court ID No. 47437
Deputy
N
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No. 11-5775 CIVIL
ALBERT R WILSON JR. tpSto ?L+^'n? ({+v ?' ??+ lr ?l S1e 7 S
Defendant(s)
MEMBERS IST FCU I S 111 S?r''t`? ??d l Utu-r <<Sle, 7p ??0/S
Garnishee(s)
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Kindly issue a Writ of Execution in the above matter...
I . directed to the Sheriff of CUMBERLAND County:
2. against ALBERT R WILSONJR , Defendant
3. against MEMBERS I ST FCU,, , Garnishee
4. Judgment Amount
Less Payments/credits received
Interest
Costs
r,n
M
M
? =r ?
=C) .
:
o
p? tv ,
?,
C r, rt
$ $14,141.99
_,adsP.?s
$ $2,083.81
$ $739.87
SUBTOTAL: $ $12,798.05
Costs (to be added by Prothonotary): $
WELTMAN, WEINBERG & REIS CO., L.P.A.
By: a/
William T. Molczan, uire
&blq. DD Q PA I.D. #47437
3?- 00 WELTMAN WEINBERG& REIS CO., L.P.A.
tt i+ 1400 Koppers Building
?'? ? 00 u ti 436 Seventh Avenue
1 ? . u Pittsburgh, PA 15219
a q ' (412) 434-7955
U. a.so p16\
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A 2' a5 DJe 6 -
0k 41668(,(61W" No. 9196695
?-v a$r,??s Wf if- dF Z?s?d
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff o� "al a�n§r l r rLEJ-0F r 1�W
Jody S Smith � � i P ; tft�?�G A'
Chief Deputy 2013 APR —5 PM 3 53
Richard W Stewart
Solicitor OMCEOFTHE SKRIFF CUMBERLAND COUNTY
PENNSYLVANIA
Discover Bank
Cass Number
vs.
Albert R. Wilson, Jr. 2011-5775
SHERIFF'S RETURN OF SERME
03/29/2012 10:31 AM-Stephen Bender, Deputy Sheriff,who being duly sworn according to law, states that on March
29, 2012 at 1030 hours, attached as herein commanded all goods, chattels, rights, debts, credits, and
monies of the within named defendant,to wit: Albert R. Wilson, Jr., in the hands, possession, or control
of the within named garnishee, Members 1st Federal Credit Union, 1711 Spring Road, Carlisle,
Cumberland County, Pennsylvania 17013, by handing to Paula Breitenbach, Customer Service
Representative, 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 30, 2012 to Albert R. Wilson, Jr., at
656 Burnt House Road, Carlisle, PA 17015.
04/05/2013 Ronny R.Anderson, Sheriff,who being duly sworn according to law, states this writ of execution is
returned as STAYED. Plaintiffs attorney collected$2,083.81 from defendant's bank account.
SHERIFF COST: $128.34 SO ANSWERS,
April 05, 2013 RON R ANDERSON, SHERIFF
,ill,*X93�
c)GountySua a 5neritt.'releosoft,Inc
WRIT OF EXECUTION and/or ATTACHMENT
A
L
COMMONWEALTH OF PENNSYLVANIA) NO 11-5775 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION—LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt,interest and costs due DISCOVER BANK Plaintiff(s)
From ALBERT R.WILSON,JR.,656 BURNT HOUSE ROAD,CARLISLE,PA 17015
(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:
MEMBERS 15T FCU,1711 SPRING ROAD,CARLISLE,PA 17013
and to notify the garnishee(s)that:(a)an attachment has been issued;(b)the garnishees) 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$14,141.99 L.L.$.50
Interest $392.88
Atty's Comm % Due Prothy$2.25
Atty Paid $171.50 Other Costs
Plaintiff Paid
Date: March 27,2012
David D.Buell,Prothonotary
(Seal) .
Deputy
REQUESTING PARTY:
Name WILLIAM T.MOLCZAN,ESQUIRE
Address:WELTMAN,WEINBERG&REIS CO.,L.P.A.
1400 KOPPERS BUILDING
436 SEVENTH AVENUE
PITTSBURGH,PA 15219
Attorney for:PLAINTIFF
Telephone: 412-434-7955
Supreme Court ID No.47437
TRUE COPY FRONT RECORD
to Tsetimony hWed.i hero'WAo set my hand
and thelp�of said 0,Pa.
This_1G. day Of P -19—T
roy
s
x
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson iw! f=D-ltl
Sheriff ' "pf cuiubtrl Cif- THE PROTHONi�TAJ,
Jody S Smith �"�� �
Chief Deputy 5— �
Richard W Stewart OF€IC FTF3€ I�lFF CUMBERLANU COUNT`
Solicitor PENNSYLVANIA
Discover Bank Case Number
vs. 2011-5775
Albert R. Wilson, Jr.
SHERIFF'S RETURN OF SERVICE
09117/2012 02:45 PM-William Cline, Deputy Sheriff,who being duly swom according to law, states that on
September 17,2012 at 1446 hours, attached as herein commanded all goods, chattels, rights, debts,
credits,and monies of the within named defendant,to wit: Albert R.Wilson, Jr., in the hands,
possession, or control of the within named garnishee, Members 1st Federal Credit Union, 1711 Spring
Road, Carlisle, Cumberland County, Pennsylvania, by handing to Melinda Wilkins, Member Service
Representative personally three copies of interrogatories Nether 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 September 18,2012 to Albert R.Wilson,jr.,
at 656 Burnt House Road, Carlisle, PA 17015.
04/05/2013 'Ronny R.Anderson, Sheriff,who being duly swom according to law, states this writ of execution is
returned as ABANDONED, No action on writ in over 6 months.
SHERIFF COST: $87.42 SO ANSWERS,
April 05, 2013 RON R ANDERSON, SHERIFF
d
fc)CountySwe Snerift,T'eleosoft,Inn
WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA) NO 11-5775 Civil
COUNTY OF CUMBERLAND) CIVIL ACTION—LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt,interest and costs due DISCOVER BANK Plaintiff(s)
From ALBERT R.WILSON,JR.,656 BURNT HOUSE ROAD,CARLISLE,PA 17015
(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:
MEMBERS 1sT FCU,1711 SPRING ROAD,CARLISLE,PA 17015
and to notify the garnishees)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$12,058.18 L.L.$
Interest $739.87
Atty's Comm % Due Prothy $2.25
Atty Paid $224.00 Other Costs
Plaintiff Paid
Date:SEPTEMBER 4,2012
qQn
.Buell,
(Seal) By: ono
De ty
REQUESTING PARTY:
Name:WILLIAM T.MOLCZAN,ESQUIRE
Address:WELTMAN,WEINBERG+&REIS CO.,L.P.A.
1400 KOPPERS BUILDING
436 SEVENTH AVENUE TRU
In TestiPITTSBURGH,PA 15219 and
dtMid tiara unto set mY hand
Attorney for:PLAINTIFF rt* Aisle,Pa.
Telephone:412-4347955 P_ 4e_
Supreme Court ID No. 47437 "� rY