HomeMy WebLinkAbout13-2401 Supreme Court "ennsylvania W RN 30088720 C A Pit SJS
Cou wof Common.Pleas
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iff_Gover Shee ForProllronorwy Use On4: 4 1.
C UMBERLAN : �i =� ` t COUII Docket No:
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77ie information collected on this form is used solely for court administration purposes. 77ris form does not
supplement or replace the filing and service of pleadings or other papers as required by law or rules of court.
Commencement of Action:
S QI Complaint ❑ Writ of Summons ❑ Petition
E Transfer from Another Jurisdiction Declaration of Takin
C Discover Bank, Throug
Lead Plaintiffs Name: Its Servicing Agent, Lead Defendant's Name:
T DB Servicing Corporation CHRISTOPHER J LUCE
I
0 Are money damages requested? ® Yes ❑ No Dollar Amount Requested: ® within arbitration limits
N (check one) ❑ outside arbitration limits
Is this a Class Action Suit? ❑ Yes 13 No Is this an 1VWJ Appeal? ❑ Yes 0 No
A
Name of Plaintiff /Appellant's Attorney: William T. Molczan,47437
❑ Check here if you have no attorney (are a Self - Represented [Pro Se] Litigant)
Nature of the Case Place an "X" to the left of the ONE case category that most accurately describes your
PRIMARY CASE. If you are making more than one type of claim, check the one that
you consider most important.
TORT (do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS
❑ Intentional Buyer Protection Administrative Agencies
❑ Malicious Prosecution Debt Collection: Credit Card ❑ Board of Assessment
❑ Motor Vehicle Debt Collection: Other ❑ Board of Elections
❑ Nuisance ❑ Dept. of Transportation
S ❑ Premises Liability ❑ Statutory Appeal: Other
B
[3 Product Liability (does not include E3 Employment Dispute
Mass tort) Discrimination
C ❑ Slander/Libel/Defamation ❑ Employment Dispute: Other ❑ Zoning Board
T ❑ Other: ❑ Other:
I ❑ Other:
O
N MASS TORT
❑ Asbestos
B ❑ Tobacco REAL PROPERTY MISCELLANEOUS
❑ Toxic Tort - DES ❑ Ejectment ❑ Common Law /Statutory Arbitration
❑ Toxic Tort — Implant ❑ Eminent Domain /Condemnation ❑ Declaratory Judgment
❑ Toxic Waste ❑ Ground Rent ❑ Mandamus
❑ Other: ❑ Landlord/Tenant Dispute ❑ Non - Domestic Relations
❑ Mortgage Foreclosure: Residential Retraining Order
❑ Mortgage Foreclosure: Commercial ❑ Quo Waranto
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PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other:
❑ Dental ❑ Other:
❑ Legal
❑ Medical
❑ Other Professional:
Updated 1/1/2011
t
NOTICE
Pennsylvania Rule of Civil Procedure 205.5. (Cover Sheet) provides, in part:
Rule 205.5. Cover Sheet
(a)(1) This rule shall apply to all actions governed by the rules of civil procedure except the
following:
(i) actions pursuant to the Protection from Abuse Act, Rules 1901 et seq.
(ii) actions for support, Rules 1910.1 et seq.
(iii) actions for custody, partial custody and visitation of minor children, Rules
1915.1 et seq.
(iv) actions for divorce or annulment of marriage, Rules 1920.1 et seq.
(v) actions in domestic relations generally, including paternity actions, Rules
1930.1 et seq.
(vi) voluntary mediation in custody actions, Rules 1940.1 et seq.
(2) At.the commencement of any action, the party initiating the action shall complete
the cover sheet set forth in subdivision (e) and file it with the prothonotary.
(b) The prothonotary shall not accept a filing commencing an action without a
completed cover sheet.
(c) The prothonotary shall assist a party appearing pro se in the completion of the form.
(d) A judicial district which has implemented an electronic filing system pursuant to
Rule 205.4 and has promulgated those procedures pursuant to Rule 239.9 shall be exempt from the
provisions of this rule.
(e) The Court Administrator of Pennsylvania, in conjunction with the Civil Procedural
Rules Committee, shall design and publish the cover sheet. The latest version of the form shall be
published on the website of the Administrative Office of Pennsylvania Courts at www.pacourts.us.
F ILED OFFICE
OF T'HE PROTHONOTARY
2013 MAY - I All I I: 15
CUMBERLAND COUNTY
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Discover Bank,
Through Its Servicing Agent,
DB Servicing Corporation
Plaintiff No: I p�7V
VS.
COMPLAINT IN CIVIL ACTION
CHRISTOPHER J LUCE
Defendant FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan,47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434 -7955
FAX: 412- 338 -7130
30088720 C A Pit SJS
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
Discover Bank,,
Through Its Servicing Agent,
DB Servicing Corporation
Plaintiff
vs. Civil Action No
CHRISTOPHER J LUCE
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 banking institution organized under .
the laws of the State of Delaware and maintains a business address of
12 Reads Way, New Castle, DE 19720.
2. DB Servicing Corporation is the servicing affiliate for Discover
Bank, f /k /a Greenwood Trust Company, an FDIC - insured Delaware State
bank. As the servicing affiliate, DB Servicing Corporation performs a
variety of services for Discover Bank including, business management
services in support of Discover Bank business lines, including, among
other things, credit cards, deposits, personal loans and student
loans, customer service, collections, credit risk, collection of
delinquent accounts and other support services. The collection of
delinquent accounts includes the right to forward the account to the
attorneys and /or collection agencies for collection and to file suit
on Discover Bank's behalf.
3. At all times pertinent hereto, DB Servicing Corporation is the
servicing affiliate for Discover Bank, in reference to Defendant
account, which is the subject of this litigation.
4. Defendant is adult individual(s) residing at 315 E COOVER ST
MECHANICSBURG, PA 17055
S. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXX7584.
6. Defendant made use of said credit card and has a current balance
due of $11045.89. A copy of Plaintiff's STATEMENT is attached hereto,
marked as Exhibit 11
7. Defendant is in default by failing to make monthly payments when
due. As such, the entire balance is immediately due and payable to
Plaintiff.
8. Although repeatedly requested to do so by Plaintiff, Defendant has
willfully failed and /or refused to pay the balance due the Plaintiff.
WHEREFORE, Plaintiff prays for Judgment in its favor and against
Defendant, CHRISTOPHER J LUCE, INDIVIDUALLY, in the amount of
$11045.89 with interest at the statutory rate of 6.00 o per annum from
date of judgment and costs.
6
Williffim T. Molc7An,47437
WELTMAN, WEINBE G & REIS CO., L.P.A.
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434 -7955
FAX: 412- 338 -7130
WWR# 30088720 C A Pit SJS
This law firm is a debt collector attempting to collect this debt for
our client and any information obtained will be used for that purpose.
New Balance Minimum Payment Due Account Number ending in 7584
DISCO $0.00 $1,922.00 Enter Amount Enclosed Below
Payment Due Date $
November 26, 2012
31 SDSN6A010008709
CHRISTOPHER J LUCE Text APP to DISCOW to receive a link to our
free mobile app and pay your bill in seconds
503 LOUISA LN from anywherel
MECHANICSBURG PA 17050 - 2433
PO BOX 6103 i��rrs��rsrsr��rsss��r��rrl
CAROL STREAM IL 60197 -6103
Address, e-mail or telephone change? � �� niinsnnrnliinisni nn niinrnss�ilinsnnn in (nnnsni�nninni)
Go to www.Discover.corn or print change in space above.
000001986458 735195980000000000000000192200
Opening Date: October 27, 2012 - Closing Date: October 31, 2012 page 1 of 2
Discover More Card Account Summary Payment Information
New Balance $0.00
Minimum Payment Due $1,922.00
Account number ending in 7584 Payment Due Date November 26, 2012
Previous Balance $11,045.89 Lab Payment Warning: If we do not receive your minimum
Payments And Credits 11,045.89 payment by the date listed above, you may have to pay a late
Purchases + 0.00 fee of up to $35.00 and your purchase and balance transfer
Balance Transfers + 0.00 APRs for new transactions may be increased up to the Penally
Cash Advances + 0.00 APR of 19.24` variable.
Fees Charged + 0.00
Interest Charged + 0.00
New Balance 0.00
Manage Your Account Online at www.Diseover.com
See Interest Charge Calculation section following Securely access statements and free online tools, pay bills
transactions for detailed APR information online and track and view all transactions simply and easily
Credit line $10,900.00 Make your money worth moresm—find easy ways to earn
Credit Line Available $OAO and redeem cash rewards
Cash Advance Credit line $5,600.00 NEW I Access your account securely through your
Cash Advance Credit Line Available $0,00 mobile phone
3 Easy Ways to Contact Us
Cashback Bo nus" Anniversary Access your account securely at www.DiKaver.com
Anniversary Month 2. Call 1- 800-DISCOVER (1- 804347 - 2683).
March Please have your Discover® card available.
Opening Cashbock Bonus Balance $ 0.00 3. Write to us at Discover PO Box 30943,
New Cashback Bonus This Period + 0.00 Salt Lake City, UT 841 (Not a payment address)
For payments, please send to address on remittance or
Cashback Bonus Balance $ 0.00 Discover, PO Box 6103, Carol Stream, IL 60197.6103
To leam mom, 69 in at www.Dinaver.com For TM (Telecommunications Device For the Deal)
assistance, please call 1- 804347 -7449.
Transactions
Trans. Post
Date Dace
Payments and Credits Oct 31 Oct 31 INTERNAL CHARGE -OFF $ 11,045.89
Fees TOTAL FEES FOR THIS PERIOD $ 0.00
Interest charged TOTAL INTEREST FOR THIS PERIOD $ 0.00
2012 Totals Year-to-Date
TOTAL FEES CHARGED IN 2012 $ 235.00
TOTAL INTEREST CHARGED IN 2012 912.IIT
30088720
NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION DISC
Paperless statements h I ilean less clutter, more convenience
Easily access up to 24 months of down%o password protected statements.
• See your statement as soon las it's ilable rather than wait for it to arrive in your mailbox.
• Get helpful payment reminders thro gh e-mail or text messages on your mobile phone.
• Print a paper copy of your #stem anytime.
• Sign up today at Discovencom/
02010 Discover Bank, Member FDIC PAPER.0310
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Questions? Visit www.Di W or DISCOVER
call 1- 800 - DISCOVER (1- 800-3j47-26 ).
DISCOVER I Itpaysro C HRISTOPHERI LUCE
DISCOVEa _j ccount .b. ending in 7584
page 2 of 2
Interest Charge Calculation
Your Annual Percentage Rate (APR) is the annual interest role on your account.
Currerd Billing Period: 5 days
TYPE OF BALANCE ANN �w (APR) B SSUIL ECi TO INTEREST CHARGE
RATE Purchases 14.24% V $0 $0
Cash Advances 20.99% $0 $0
V - Variable Rate
Additional Important Information
See your Cardmember Agra nm ». Your Cardmember Agreement contains all the terms of your Account.
Lost or stolen cards. Report immediatelyl Cal 1.800.347.2683.
What To De tf 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, Sant lake City, UT 841304421
In your letter, give us the Following information:
Account information: Your name and account number.
Dollar amount The dollar amount of the suspected error.
ft sc �io�n of Problem: 1F you think then is an error on your bill, describe what you believe is wrong and why you believe
i isF' 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 writin You m ay call us, but if you do we are not required to Investigate any
potential errors and you may have to pay et�amount in question.
While we investigate whether or not there has been an error, the Following are true:
We cannot by 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 an responsible for the remainder of your balance.
We can apply any unpaid amount against your credit limit.
Y_ _our Riahb if You Are Dissatisfied With Your Credit Card Purchases
If you ore 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 Fallowing must be true:
1 The purchase must have been made In your home state or within 100 miles of your current mailing address, and
the purchase price must have been more than $50. (Note: Neither of these are necessary if your purchase was
based on an advertisement we mailed to yyoou , or if we own the company that sold you the goods or services.)
2. You must have used your credit cord for the purchase. Purchases made with cash advances from an ATM or with a
check that accesses your credit card aaounf 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 writin at:
Discover, PO Box 30945, Salt lake Ci yi , UT 84130-0945
While we investigate, the same rules apply to the disputed amount as discussed above. Aker 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.
Paymsnh You may all or pat of your Account balance at arty time. However, you must pay at least the Minimum
Payment Due by the f enf Due Date. Send only your payment and the top portion of this statement in the envelope
provided. Do not send cash. B sending your check as described above, you authorize us to use information on your cheek
to make an electronic fund transfer from your axount at the financial institution indicated on your check or to process the
payment w a cheek transaction. If payment is processed as an eleetronte fund transfer fha transfer will be For the amount of
Itro check. When we use information From your cheek to make an electronic fund hans�er, Funds may be withdrawn from your
account
as soon as the same day we receive your payment, and you will not receive your cheek back from your financial
institution.
The processing of r payment may be delayed if you send cash, eorrospondenee or other items with your payment, if you
send the payment 10 any ot:'I address or if you u» an envelope otter than the one provided. Paymenla reeerved m proper
farm at our processing Faciby 5PM local time on any day will be credited to your AeeauM as of that day. Payments
received at our processing after SPIN local time will be credited to your Aeeount as of the next day. If you haw
misplaced yyoour envelope, send your payment to Discover PO Box 6103 Carol Stream, IL 60197 6103. Please allow 7.10
days (or del'iwry. IF your payment is retained unpaid, wsi reserve the rig�it to rewbmit it as an elecroronie debit.
30088720
NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION DISC
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You can pay r monthly Minimum Payment or greater amount that does not exceed your current Account balance,
over the tele a or you can setup outom ' through a customer service representative by calling
1$00-347- 683. Automatic payments will b# on the Payment Due Date unkass you request a recurring payment
date (e. . the 15th day of the month) that oc be your Payment Due Date. If your scheduled payment date falls on a
weekend or bank holiday, your payment will prat the business day for to the weekend or bank holiday. In order
to schedule monthly payments b t��� wifl this statement and jrour bardx account information. You will be
asked to provide the last four (4�digih of the $acid iy number of the primary borrower. By providing those number as
your electronic signature, you will be agree inrrgg to thia nzation to allow us and your bank to deduct each payment you
authorize, in the amount selected by you, front your account. You also authorize us to initiate debit or credit entries to
your bank account, as applicable, o correct �n error i the processing of such payment. You can cancel a scheduled
payment by phone at 1 - 800 347 - 2683 or b jrrall at ver, PO Box 30421 Sah lake City UT 84130-0421, however we
must receive notice at least three business days in of the scheduksd payment. If your payments may vary in amount,
we will tell you on each monthly billing statenrlsrtf when r payment will be made and Now much it will be. You must ensure
that sufficient Funds are available in your bent) account and all transactions must comply with U.S. law.
You can set automatic payments For (i) stahrtlerll lance, (ii) statement Minimum Payment Due, (iii) statement Minimum
P Payment Due plus a fixed dollar amount, or (1Y) a fixed Par amount. IF your scheduled fixed payment is not enough to cover
Minimum Payment Due as listed on your omhly i statement, your scheduled payment for that month will be
increased to cover the Minimum Payment Ou If fhs uled payment is greater than the Minimum Payment Due, any
excess will be applied in accordance with your bar Agreement. It your scheduled payment is greater than the New
Balance on your billing statement, that payment will ocessed only for the amount of your New Balance. Your automatic
enI amount may be less than the amount indi on the periodic statement based on credits or payments after the
losing Date.
IF you enroll by phone in our automatic payment servig o, please fill -in the following blanks below and retain the authorization
for your records.
Amount: ❑ Full Pay ❑ Min Pay Min Pay + s ❑ Fixed Pays rn
Bank Routing #: Bank A xount #: Frequency: Z
Crod't Reporting. We may report infonnati about Aeeount to credit bureaus. hate enfs, missed payments, or o
other defaults on your Account may be rofl in credit report. We normally report�fhe�stafus and payment history of
your Account to credit reporting agencies mortllt If ou believe that our report 13 inaccurate or incomplete, please write 0 0
us of the following address: Discover, PO 15316 WYmington, DE 19850-5316. Please indicate your name, address, C.
home telephone number and Account numbs}'. o
ro
Payng M.rest Webeg into impose interr� ehargesl a transaction fee or inMrest charge From the day we add it to the
daily balance. We continue to impose interdd a until you pay fie total amount you owe us. You can avoid paying
interest on Purchases as described beksw. hlovvsver, cannot avord paying interest on Balance Transfers or Gash
Advances.
How to Avoid Psdno Interest on Purchases P od"
It you paid the New Balance on your prove billialS mert by the Payment Due Date shown on that billing statement, we
will not impose interest charges an new or ray portion of a new Purchase, paid by the Payment Due Date on your
current billing statement. New Purchases that first appear on the cut billing statement.
How We Aoo1v Payments M Ica ct Your • ad
it you not pay your ew ace n m then, depending on the balance to which we apply your payment,
you may not get a grace period on new Pu
How We Calculate Interest Charges Daly ad (ircludirg current transactions): We calculate interest charges
each billing period by first figuring the "der bal for each Transaction Category. Transa Coteyories include
standard Purchases, standard Cash Ad and di nt promotional balances, such as Balance Transfers.
How We Figure the Daily balance for EoA Calsgery
We start with the beginning balance for eaeF� The beginning balance for the first day of the billing period is
your balance on the ast day of youmnpr vious iI mg perioodd
We add any interest charges ace an the ious days daily balance and any new transactions and fees. We
add anyy new transactions w fees as of the I of the Transaction Date or the first day of the billing period in
which the transaction or fee posted your cunt.
We subtract any new credits and pgymenh. .
We make other adjustments (including those' justments required in the "Paying Interest" section).
How We Figure Your Total kderect Cbargesi
We multiply the daily balance for rill T on Category by ifs daily odic note. We do this For each day in
the billin period. This gives us the as for each Transaction at To get a daily periodic rate,
we divide CAR Ihat applies to Tw Category by 365.
We add up all the daily interest chajrgss. sum is the total interest charge for the billing period.
Now We "d• Fees
We add Balance Transfer Fees to the appli
46 Transfer Transaction Category We add Cash Advance
Fees to the applicable Cash Advance Tra 'on ry, We add all other fees to the standard Purchase
Transaction Category.
Balance Subject to Interest Rate. Your staieMtsrt sho is a Balance Subject to Interest Rate. It shows this for each
transaction category. The Balance Subject loo Interes Rate is the average of the daily balances during the billing
period.
Credit balances. If your Account has a c M bola , the amount is shown on the Front of your billing statement.
A credit balance is money that is owed to ou. You ay make charges against this amount if your Account is
open. We will send you a refund of any r•jmaininrg lance of $1.00 or more after 6 months, or as otherwise
required by applicable law.
For MD ((T Q e leca q m / i�unicalions Device for tlrj DawQ ce, please call 1. 800. 347.7449.
Distb rr7aMtor and /or record tebpKons a between you and Discover representatives for quality assurance purposes.
The Dixover is issued by Discover Bonk, r FDIC RZNFEOO1
Questions? Visitwww.Di
cc
r DISCOVER
call 1-800•DISCOVER (1- 800 34 -2683 .
VERIFICATION
'c.ou
(Name) (Title)
of DB Servicing Corporation, servicing affiliate of Discover Bank does hereby verify, under penalty of
perjury and subject to the penalties of 18 Pa. C.S. § 4904 relating to unswom falsifications to authorities
states, that he /she is a duly authorized representative of plaintiff herein. Additionally, he /she verifies that
Discover Bank, f/k/a Greenwood Trust Company, which is an FDIC - insured Delaware state bank, lacks
sufficient knowledge or information to verify this complaint. He /she verifies that he /she is authorized to
make this verification. As an employee of DB Servicing Corporation, he /she has sufficient knowledge
and information to make this verification, and consequently verifies that the facts set forth in the
foregoing complaint are true and correct to the best of his/her knowledge and information and that he /she
is personally familiar with the account and the relationship between Discover Bank and DB Servicing
Corporation.
It is further stated that Discover Bank and DB Servicing Corporation extend credit through issuance of the
Discover Card. As the servicing affiliate, DB Servicing Corporation performs a variety of services for
Discover Bank, including business management services in support of Discover Bank business lines,
including, among other things, credit cards, deposits, personal loans and student loans, customer service,
collections, credit risk, collection of delinquent accounts and other support services. The collection of
delinquent accounts includes the right to forward the same to the attorneys and/or collection agencies for
collection and to file suit on Discover Bank's behalf. Both DB Servicing Corporation and Discover Bank
are wholly owned subsidiaries of Discover Financial Services.
Date
(Signature)
DB Servicing Corporation servicing affiliate
For Discover Bank
PO Box 3025
New Albany, OH 43054
30088720
I
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith t?i ��y P�
Chief Deputy 1 t
C(,►+��
Richard W Stewart ' " '
EPL, "1
Solicitor =.aEFr PEfvtJS ('VA Pal t
Discover Bank Case Number
vs.
2013-2401
Christopher J Luce
SHERIFF'S RETURN OF SERVICE
05/02/2013 03:07 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint&
Notice by handing a true copy to a person representing themselves to be Mary Kay Boles, Mother of
defendant,who accepted as"Adult Person in Charge"for Christopher J Luce at 315 E. Coover Street,
Mechanicsburg Borough, Mechanicsburg, PA 17055. �f
J SON KINSLER, DEPUTY
SHERIFF COST: $39.30 SO ANSWERS,
May 03, 2013 RbNW R ANDERSON, SHERIFF
'F tL.E0-0rr;�..�
117 � FOfft i.
i t{L + 7
013 MAY 31 AM 1 : 23
CUMBERLAND COUNTY
WELTMAN,WEINBERG & REIS CO., L.P.A. PENNSYLVANIA
BY: William T. Molczan Attorney for Plaintiff(s)
I.D. No. 47437
436 Seventh Avenue 1400 Koppers Building
Pittsburgh, PA' 15219
Phone: (412) 434-7955
Fax: (412) 338-7130
File# 30088720 WTM/SJS
Discover Bank, Through Its Servicing Agent
DB Servicing Corporation Cumberland County
Court of Common Pleas
vs.
No.: 13-2401 CIVIL
CHRISTOPHER J LUCE
PRAECIPE TO DISMISS WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Kindly dismiss the above matter without prejudice .
WELTMAN, WEINBERG&REIS CO., L.P.A.
By
William T. Molczan, Es ire
Attorney for Plaintiff