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HomeMy WebLinkAbout11-5775C') rv C? z? c x ?-n rn ? --<b t N o c x 2: 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 Ck ? s'??P?QZ e4 ?4 a-() 73 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 w O rn Z m o_ 0 0 0 rn A J A N X 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): Q 3y oo ?8w ?. as « « VA.60 Lt L,( i o r.: x> rn? ? -<> F-- -.i D ? m za ?,, c Ica $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. L" k?? ??r?u??S p? a73o0? WWR No. 9196695 ?1+ s?? 1U, ?& 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 ??-? ? S_ l y)h U IN ? i 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\ ? 2a`-1. pO 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