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HomeMy WebLinkAbout11-7014FILED-OFFICE OF THE PROTHONOTIO ' 1011 SEP -9 PM 12: 37 CUMBERLAND COUNTY PENNSYLVANIA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. BARBARA A GOLDEN Defendant No: //_ 70/y el?,? 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 09281347 C A Pit SJS ? 9z e ? /oioss79 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No BARBARA A GOLDEN 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: BARBARA A GOLDEN 1008 ALEXANDER SPRING RD CARLISLE, PA 17015 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX3699 . 4. Defendant made use of said credit card and has a current balance due of $1950.22 , as of June 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 19.990. per annum on the unpaid balance from June 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 , BARBARA A GOLDEN INDIVIDUALLY , in the amount of $1950.22 with interest at the rate of 19.990% per annum from June 30, 2011 plus attorneys' fees of $125.00 , and costs. o t,42524 James C. a 7Ae WELTMAN, RG & REIS C O., L.P.A. 436 Sev nt nue, Suite 1400 Pittsb gh, 15219 (412) 34-7 FAX: 12-3 8-7130 09281 47 A Pit SJS This law firm is a debt collector attem i to collect this debt for our client and any information obtained w' 1 be used for that purpose. DISCOVER` $000 lance 30 SDSN6A010004122 BARBARA GOLDEN 1008 ALEXANDER SPRING RD CARLISLE PA 17015-9312 Tired of buying stamps? Go mobile! Make payments from your phone with the Discover app. It's fast and It's free. Download today at http://www.discover.com/apps PO BOX 6103 Illrrrll,rrrrllJl,rrl,rJl CAROL STREAM IL 60197-6103 CA11 change? Go Address, to www-Dioil oseoyew telephone Irllr?llirrrrrl?lrlrrlrrrlillirrrrlll?rrrirllrllrrrirl?rrlrill or.eom or one print change in space above. 000001986458932066133000000000000000031900 Opening Date: June 28, 2011 Closing Date: June 30, 2011 r Discover More Card Account Summary Account number ending in 3699 Previous Balance $1.950.22 Payments And Credits 1,950.22 Purchases + 0.00 Balance Transfers + 0.00 Cash Advances + 0.00 Fees Charged + 0.00 Interest Charged + 0.00 _0? See Interest Charge Calculation section followin transactions for detailed APR information g Credit Line $1,500.00 Credit Line Available $0.00 Cash Advance Credit Line $800.00 Cash Advance Credit Line Available $0.00 Anniversary Month January Opening Cashback Bonus Balance $ 0.00 New Cashback Bonus This Period + 0.00 Cashback Bonus Balance $ 0.00 To leorn more, log in al www.Discover.com Transactions Dace 1 of 9 Payment Information New Balance $0.00 Minimum Payment Due $31900 Payment Due Date July 28, 2011 Late Payment Warning: If we do not receive your minimum payment by the date listed above, you may have to pay a late fee of up to $35.00. 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 • NEWI Access your account securely through your mobile phone 3 Easy Ways to Contact Us 1 Access your account securely at www.Discover,com 2. Call 1.800-DISCOVER (1.800.347.2683 Please have your Discover* card availab e. 3 Write to us at Discover PO Box 30943, Salt Lake City, UT 84130 (Not a payment address) For Discovvern PO Box 6103, Carol Stream, IL 60197.6103 For TDD ffelecommunIcations Device for the Deaf) assistance, please call 1-800.347-7449. Trans. Post Date Date Payments and Credits Jun 30 Jun 30 INTERNAL CHARGE-OFF $ 1.950.22 Fees TOTAL FEES FOR THIS PERIOD $ 0.00 Interest Charged TOTAL INTEREST FOR THIS PERIOD $ 0.00 2011 Totals Year-to-Date TOTAL FEES CHARGED IN 2011 TOTAL INTEREST CHARGED IN 2011 9281347 $ 210.00 173.21 Minimum Payment Due I Account Number ending in 3699 $319.00 Enter Amount Enclosed Below Payment Due Date July 28, 201 1 $ c. Jcr RcvtK,)t Slut FOR IMPORTANT INFORMATION DISCOVER` It pays to BARBARA GOLDEN -QlSIC(i ER__ Account number ending in 3699 Interest Charge Calculation page 2 of 2 Your Annual Percentage Rate (APR) is the annual interest rate on your account. Current BRling Period: 3 days TYPE OF BALANCE ANNUAL PERCENTAGE BALANCE SUBJECT TO INTEREST CHARGE RATE (APR) INTEREST RATE Purchases 19.99% $0 $0 Cash Advances 19.99% $0 $0 V = Variable Rate Additional Important Information See your Cardmemf»r Agreement. Your Cardmember Agreement contains all the terms of your Account. Lost or stolen cards. Report immediatelyl 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 Salt 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 Description of Problem: If you think there is an error on your bill, describe what you believe is wrong and why you believe it is a mistake. 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 question may remain on your statement, and we may continue to charge you interest on that amount. But, if we determine that we made 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 Rights ff You Are Dissatisfied With Your Credit Card Purchases If you are dissatisfied with the goods or services that you have purchased with your credit card, and you have 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: 1 The purchase must have been mode 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 ore necessary if your purchase was based on on 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, Salt Lake City, UT 84130.0945 While we investigate, the same 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 on 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 an electronic fund transfer From your account at the financial institution indicated on your check or to process the payment as a check transaction. li 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 same day we receive your payment, and you will not receive your check back from your financial institution. The processing of your payment may be delay yed if you send cash, correspondence or other items with your payment, if you send the payment o any other address or i f use an envelope other than the one provided. Payments received in proper form at our processing facty by SPM local time on any d ayy will be credited to your Account as of that day. Payments received at our processing facty offer SPM local time will be credited to our Account as of the next day. If you have mis p laced your envelope, send your payment to Discover, PO Bax 6103, Carol Stream, IL 601 97-6 1 03. Please allow 710 ys or deli very. If your payment is returned unpaid, we reserve the right io resub d amit it as an electronic debit. You can pay your minimum payment or a greater amount over the telephone, and you can set up automatic payments. Call us at 1-800.347.2683. You will need this statement and your bank account information. You must ensure that sufficient Funds are available in your bank account, and all transactions must comply with U.S. law. You will be asked to provide the first S digits of your account statement ZIP code. % entering those numbers as your electronic signature, you will be agreeing to this authorization to allow us and your bank to dye duct each payment you authorize from your bank account, and to initiate debit or credit entries to your bank account, as o plicabie, to correct an error in the processing of such payment. You must tell us the amount of eacft payment or you can select on amount such as the Minimum Payment Due or the New Balance on each statement. You can cancel a payment; however we must receive notice at least three business days in advance of the scheduled pa ment.pYou may notify us by phone at 1-800.347-2683 or by mail at the address listed in the previous our and how much it will be. Y ur automatic pamount yment almolunt may be less tha indicated on the monthlysta ementilbased ode credits or payments applied during the billing cycle. Credit Reporting. We may report information about your Account to credit bureaus. Late payments, missed payments, or other defaults on your Account may be reflected in your credit report. We normally report the status and payment history of yp} 7gdtfa credit reporting agencies each month. If you believe that our report is inaccurate or incomplete, please write TM1? h5116(vmg address: Discover, PO Box 15316, Wilmington, DE 1 9850-5 3 1 b. Please indicate your name, address, home telephone number and Account number Paying Interest. Except as provided below, we will impose Interest Charges on purchases, cash advances and balance transfers beginning with the date the transaction occurs until the date of repayment and on Old Balances, until the date of repayment. Old Balances are comprised of either purchases and cash odvonces made on or prior to the last day of your billing period ending during February 1993 or Reserve line balances. You can avoid payment of Interest Charges on new purchases if you pay the New Balance shown on the billing statement on which the purchase first appears by the Payment Due Date, and the Payments and Credits on that statement equal or exceed your Previous Balance. We call this the "grace period" You do not have a grace period on balance transfers or cash advances. Interest Charges are imposed on new balance transfers and cash advances beginning with the date the transaction occurs. NOTICE SEE REVERSE SIDE FOR IMPORTANT INFORMATION Interest Charges are imposed on all transactions and Old Balances until the date of repayment. Repayment means payment of your entire New Balance. However, if you pay the New Balance shown on this billing statement by the Payment Due Date, and the Payments and Credits shown on this statement equal or exceed the Previous Balance, we will not impose Interest Charges on new purchases, that is, purchases first appearing on this statement. If your Account was closed as of September 27 1999 you can avoid payment of Interest Charges if you pay the New Balance shown on this Statement by the Payment Due Date and the Payments and Credits on this Statement equal or exceed your Previous Balance. Otherwise, you will receive a billing statement next month that includes Interest Charges imposed until the date of repayment. How We Calculate Interest Charges Daily Balance Method (including current transactions): We figure Interest Charges for each billing period. To do this: We calculate your Interest Charges separately for each balance subject to different terms (for example, standard Purchases, standard cash advances and Old Balances and each purchase, balance transfer and cash advance balance subject to promotional terms(. We refer to these balances as transaction categories. We figure the "daily balance" for each transaction category. To get the "daily balance" we take the beginning balance for each day, add any new transactions and fees and any Interest Charges accrued on the previous day's daily balance. We then subtract any credits and payments and make other ad'ustments. In calculating the daily balance for the first day of the billing period, we consider the "previous day's ?aily balance" to have been your balance on the last day of your previous billing period. This gives us the daily balance for each transaction category. We figure the Interest Charges on your Account by multiplying the daily balance for each transaction category by its daily periodic rate, for each day in the billing period. The total Interest Charges for the billing period are the sum of the daily Interest Charges for each transaction category for each day during that billing period. W unless the hen we calculate daily balances, we add a new transaction as of the Transaction Date shown on your billing statement, transaction rwill bet added to thetdailyubalance nasof the first day fothe f the bilbillinling period in which occurs, is posted to which yourr Account, All fees charged to your Account are added to the standard purchase transaction category with the exception of Cash Advance Fees which are added to the applicable cash advance transaction category and Balance Transfer Fees which are added to the applicable balance transfer transaction category. For TDD (Telecommunications Device for the Deaf) assistance, please call 1-800.347.7449. Discover may monitor and/or record telephone calls between you and Discover representatives for quality assurance purposes. The Discover©card is issued by Discover Bank, Member FDIC OITBK06o 9281347 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 unworn falsifications to authorities, that she is Natasha Szczygiel, Legal Placement Account Manager (Name) (Title) of DB Servicing Corporation successor to DFS Services LLC servicing agent for Discover Bank (Company) plaintiff herein, that she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of her knowledge, information and belief. WV,/R# 9281347 Barbara A. Golden 6011002820653699 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny RAnderson H? s= i nc r? Sheriff Jody S Smith G . _.?) # ?? 26 P 2? Chief Deputy Richard W Stewart CUMBERLA14U COUNT Y Solicitor -,FFi,F.??'k.F-RIFF PENNSYLVA111A Discover Bank Case Number vs. Barbara A. Golden 2011-7014 SHERIFF'S RETURN OF SERVICE 09/13/2011 06:16 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on September 13, 2011 at 1816 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Barbara A. Golden, by making known unto herself personally, at 1008 Alexander Spring Road, Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to her personally the said true and correct copy of the same. NOAH CLINE, DEPUTY SHERIFF COST: $34.00 September 14, 2011 SO ANSWERS, RON ~ R ANDERSON, SHERIFF (ci count &Alo Shenrf, Ielw,,5oft, Inc DISCOVER BANK Plaintiff vs. BARBARA A GCS ,DEN TO THE PROTHONTARY: IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA, CIVIL DIVISION s3L\ INIA Civil Action No. 11-7014 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant BARBARA A GOLDEN above named, in the default of an Answer, in the amount of $2200.69 computed as follows: Amount claimed in Complaint $1950.22 Less payments / adjustments made $0.00 Interest on the remaining principal balance from June 30, 2011 to October 26, 2011 @ the interest rate of 19.990% per annum $125.47 Attorney's fees $125.00 TOTAL $2200.69 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. W ro t,4 09281347 Pit SJS Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburg,, A 15219 And that the last known address of the Defendant is BARBARA A GOLDEN 1008 ALEXANDER SPRING RD CARLISLE, PA 17015 4 -g /q.o°PQ'1'"6 C 1007S647 ? ?- ?. 6 G 993 /o?{ r e AW60(l IN THE COURT OF COMMON PLEAS CUMBERLAND COUN'lY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. BARBARA A GOLDEN De`9ndant Case No. 11-7014 CIVIL TERM IiiAPORTANT NOTICE O: BARBARA, A GOLDEN 1008 ALEXANDER SPRING RD CARLISLE, F-,\ 17015 Date of Notice: I D YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU, UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A FEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD 70 HIRE A LA" VYER, THIS OFFICE MX.i BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES -T'HA i MAY OFFER +-EGAL SERVICES O ELIGIBLE PERSONS AT A REDUCED FFE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BECFORD STREET CARLISLE. PA. 17013 (717) 249-x166 WELTMAN VVEINBERC' & REIS CO., L.P.A. Matti -w Urb=an P.A.I.L. # 9')96' WELTMAN, WEINBERG & F',EIS CO., L.P,A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 (4121338-7130 0281347 A PIT M4Z IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 11-7014 CIVIL TERM BARBARA A GOLDEN NON-MILITARY AFFIDAVIT The undersigned is the duly authorized agent and/or attorney for the Plaintiff in the within matter and states as follows: Affiant states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant , BARBARA A GOLDEN is not in military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the DMDC does not possess any information indicating that the below individual is in the military service: BARBARA A GOLDEN 1008 ALEXANDER SPRING RD CARLISLE, PA 17015 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 Aid& Military Status Report Pursuant to the Service Members Civil Relief Act IF Page 1 of 2 Oct-31-2011 05:28:38 Last `Name First/Middle Begin Date Active Duty Status l Active Duty End Date Service Agency GOLDEN BARBARA 'I'l Based on the information you have furnished, the DMDC does not possess any information indicating -the individual status. Upon searching theinformation data bapks 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, Nagy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). Au? Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA ' 1.2209-2593 The Defense Manpower Data Center (DMDC) is an organization o('the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DE'ERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The OoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as tree Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has ;ssued i,undr°ds of thousands of "does rift 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 b- ontacting that person's Service via the "defense]ink.mil" URL http:i!uti?tiv.dete?t ;elin,,tnilrf 'P; 't 0?) ;i 13I l ttrll If you have evidence the person is -gin activ,- dut, and you fail to obtain ti ?s additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain addNona; information about the person (e.g., an SSN improved accuracy of D013, a middle name), you can submit your request again at this Web site a?id 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 do.ys. For historical information, please contact the Service SCRA points-of- contact. httnc•//NA,",w (!rude.. ncrl m*;?/anni/.ccra/nnnr?nnrt ;;n 1 WW1 /,?O1 1 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. Phis 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 (NOAH 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 ir, some cases and includes some categories of persons on active duty for purposes of the SCRA who would nOL be -eported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. i'ersons seeking to rely on this website certif cation 1111,ould check to make sure the orders on which S(-.'RA protections are based have not been amends-d 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 inductee:, but who have not actually begun ,ctivc duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond Lhe last dates of active duty. Those -,v,ho would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report IDAN6T'SAV2FT httnc•//www !mdc.r?cf.m '/anni/ccra/nn?rennrt.?fn 1O/;l/?011 DISCOVER BANK Plaintiff vs. BARBARA A GOLDEN IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Civil Action No. 11-7014 CIVIL TERM NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the fol o ing order of Judgment was entered against you on (xx) Assumpsit Judgment in the amount of $2200.69 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 ( ) Arbitratioil Prothonotary By: BARBARA A GOLDEN 1008 ALEXANDER SPRING RD CARLISLE, PA 17015 Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 11-7014 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK Plaintiff (s) From BARBARA A. GOLDEN, 1008 ALEXANDER SPRING 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 $2,200.69 Interest $45.95 Atty's Comm % Atty Paid $171.50 Plaintiff Paid Date: March 27, 2012 (seal) L.L.$.50 Due Prothy $2.25 Other Costs David D. Buell, Prothonotary 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 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 11-7014 CIVIL TERM BARBARA A GOLDEN ! C08 A lerandee SFr S"Defendants vv `' n r -nu:; MEMBERS I ST FCU I -7 I f L?j ?0?, &r tiSle 170I3 -Mm ?' r Garnishee(s)_ r") PRAECIPE FOR WRIT OF EXECUTION o .?, TO THE PROTHONOTARY: C--) Kindly issue a Writ of Execution in the above matter... n 1, directed to the Sheriff of CUMBERLAND County: 2. against BARBARA A GOLDEN , Defendant 3. against MEMBERS 1 ST FCU,, , Garnishee 4. Judgment Amount Less Payments/credits received Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): tct? v?. co H, oo <<?? ?l?i . sa t? ?1 $ $2,200.69 cy c-; $ $0.00 $ $45.95 $ $2,246.64 WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. Molczan, Esqu' 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. 9281347 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 11-7014 CIVIL TERM vs. PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) BARBARA A GOLDEN Defendant(s) MEMBERS 1 ST FCU 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. 9281347 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson r z ' Sheriff r ,?; - Jody S Smith `= r' Chief Deputy end Richard W Stewart w - a Solicitor - -; Discover Bank Case Number vs . Barbara A. Golden 2011-7014 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: Barbara A. Golden, 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 Barbara A. Golden at 1008 Alexander Spring Road, Carlisle, PA 17015. SO ANSWERS, 6Z March 30, 2012 RON R ANDERSON, SHERIFF ephen Bender, 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 # 9281347 DISCOVER BANK vs. BARBARA A GOLDEN, and MEMBERS 1 ST FCU Garnishee(s) Attorney for Plaintiff(s) r - rt t :no -=c) CUMBERLAND County Court of Common Pleas NO. 11-7014 CIVIL TERM PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the above matter discontinued and ended as to Garnishee(s), MEMBERS 1 ST FCU,, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By Matthew D. Urban, Esquire Attorney for Plaintiff $q.5o P&A7r l ?? tosaa?aa _____._ SHERIFF'S OFFICE OF CUMBERLAND COUNTY ,nderson ~~ ~ ~~~~'1~~~ tCE Smith Jeputy ,lard W Stewart ~licitor its ~ 2 NOV - I PM ~~ 17 PENi~SYLV~aNI~ Discover Bank vs. Barbara A. Golden SHERIFF'S RETURN OF SERVICE Case Number 2011-7014 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: Barbara A. Golden, 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 Barbara A. Golden at 1008 Alexander Spring Road, Carlisle, PA 17015. 10/29/2012 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $88.38 SO ANSWERS, October 29, 2012 RON R ANDERSON, SHERIFF ~ . ~Pd . Co. ~~ ~~~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA DISCOVER BANK VS. NO. BARBARA A GOLDEN PRAECIPE FOR APPEARANCE TO THE PROTHONOTARY: Please enter my appearance for DISCOVER BANK in the above case. Date: December 18, 2014. 2011-7014 Print Name Eltman, Eltman & Cooper, PC Firm 140 Broadway, 26th Fl Address New York, NY 10005