HomeMy WebLinkAbout13-2859 Supreme Court,-of-,Pennsylvania wWR0 09721050 C A Pit SJS
Cou l of Common Pgeas
y -, � t
/ Wivi1 Gover- -Sheet ForProtkonotaq Use Ontr:
C UMBER LANI ` ,; :
Count Docket No: <
The information collected on this form is used solely for court adminish'ation pu iposes. T his Jbr does not
supplement or replace the filing and service of'pleadings or other papers as required by lax or rules of count.
Commencement of Action:
S Qf Complaint ❑ Writ of Summons ❑ Petition
E Transfer from Another Jurisdiction Declaration of Takin
C DISCOVER BANK
Lead Plaintiff s Name: Lead Defendant's Name:
T AUGUSTA R MCALHANY
I
0 Are money damages requested? El Yes ❑ No Dollar Amount Requested: ® within arbitration limits
N I (check one) ❑ outside arbitration limits
A Is this a Class Action Suit? 13 Yes 13 No Is this an MDJ Appeal? 13 Yes 63 No
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
E
E3 Product Liability (does not include [3 Employment Dispute
Mass tort) Discrimination
C ❑ Slander/Libel/Defamation ❑ Employment Dispute: Other ❑ Zoning Board
T ❑ Other: ❑ Other:
I
O ❑ Other:
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
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❑ Legal
❑ Medical
❑ Other Professional:
Updated 1/1/2011
PH
PENtF S IYD CpU
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK Q �j
Plaintiff No:
VS.
COMPLAINT IN CIVIL ACTION
AUGUSTA R MCALHANY
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
09721050 C A Pit SJS
116&6BYY
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No
AUGUSTA R MCALHANY
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 408 S FAYETTE ST #2
SHIPPENSBURG, PA 17257
5. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXX1021.
6. Defendant made use of said credit card and has a current balance
due of $2436.02. A copy of Plaintiff's STATEMENT is attached -.hereto,
marked as Exhibit
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, AUGUSTA R MCALHANY, INDIVIDUALLY, in the amount of $2436.02
with interest at the statutory rate of 6.00 o per annum from date of
judgment and costs.
Wil iam T. Mo czan,4 37
WE it, WEINBERG EIS CO., L.P.A.
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434 -7955
FAX: 412 338 -7130
WWR# 09721050 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.
DISC 'VER New Balance I Minimum Payment Due I Account Number ending in 1021
$2,500.30 $2,500.30 Enter Amount Enclosed Below
Payment DueDate
I DUE IMMEDIATELY
08 SDSN6A01 0003816
AUGUSTA MCALHANY Text APP to DISCOV* to receive a link to our
110 E BURD ST tree mobile app and pay your bill in seconds
SHIPPENSBURG PA 17257 -1304 from anywherel
PO BOX 6103 Ill+++ll+ull +nlul.ul+ll
CAROL STREAM IL 60197 -6103
Address, e-mail or telephone p (+ Il++ ll+ rr +Ir lllrlr+lr + +I+ll +�� +rllllrrr+ +lull +�� +rllr�l�+ll
Go to www.Discover.<om or print rim change in space abov
0000019864599044704360 5003000000000250030
i Opening Date: June 1, 2012 - Closing Date June 8, 2012 page 1 of 2
Discover More Card Account Summa
[ y Payment Information
New Balance $2,500.30
Account number ending in 1021 Minimum Payment Due* $2,500.30
Payment Due Date DUE IMMEDIATELY
Previous Balance $2500.30 1 *Includes past due amount of $706.00
Payments And Credits 0.00
Purchases + 0.00 late Payment Warning: If we do not receive your minimum
Balance Transfers + I 000 payment by the date listed above, you may have to pay a late
Cash Advances + 0 fee of up to $35.00 and your purchase and balance transfer
Fees Charged + 000 APRs for new transactions may be increased up to the Penally
Interest Charged + � APR of 20.99% variable.
New Ba oncl a 21500.30
See Interest Charge Calculation section fallowing Minimum Payment Warning: If you make only the minimum
transactions for detailed APR information ! paymed each period, you will pay more in interest and it will
take you longer to pay off your balance. For example:
Credit Line $21500.00
Credit Line Available $0.00 dIttvnpf chGrges bo(tirtce a p vA pnpytB nand
Cash Advance Credit Line $0.00 using dhl }card apd this stotkmedf itt estimated ttNq) of .
Cash Advance Credit Line Available
$0.00 teioiii: <yoii}ay: .ahoy)
Only the minimum 4 ears
Cosh ba Bonus' payment y $2,500
Anniversarly Month
July If you would like information about credit counseling services,
Opening Cashbock Bonus Balance $ j 0.00 call 1. 800.347.1121
New Coshback Bonus This Period + 1 0.0
Cashbock Bonus Balance $ 0.00
To learn more, log In at www.Discovercom
3 Easy Ways to Contact Us Manage Your Account Online at www.Discover.com
1 Recess your account securely at www.Discover�eom
2. Call 1.800 DISCOVER (1 Access free online tools like Paydown Planner to create a plan
- 800347.2683) to ay down your balance, securely access statements, pay
Please have your Discover®card available.
p
3. Write to us at Discover, PO Box 30943, bills online and easily track all transactions
Salt Lake City, UT 84130 (Not a payment oddr * Make your money worth moresm—find easy ways to earn
For payments,� p?Iease send to address on remittanc or and redeem cash rewards
Discover • PO Box 6103, Carol Stream, IL 601976 03 * NEWI Access your account securely through your
For TDD (Telecommunications Device for the Deaf) mobile phone
assistance, please call 1- 800 -347 -7449.
Transactions
9721050 Trans. te
Fees TC TAL FEES FOR THIS PERIOD $ 0.00
Interest Charged TC TAL INTEREST FOR THIS PERIOD $ 0.00
2012 Totals Year -to -Date EXHIBIT
T TAL FEES CHARGED IN 2012 $ 175.00
T TAL INTEREST CHARGED IN 2012 205.80
NOTICE: SEE REVERSE SIDE FOR IMPORTANT INF RMATION DISCOVER
Paperless stateme s mean less clutter, more convenience
Easily access up to 24 months of ownloadable, password protected statements.
• See your statement as soon it's available rather than wait for it to arrive in your mailbox.
• Get helpful payment remind through e-mail or text messages on your mobile phone.
• Print a paper copy of your s ement anytime.
• Sign up today at Discovers /papedess
02010 Dixover Bank, Member FDIC
.__ PAPEP 0310
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9721050
Questions? Visit wwwA er.com or
call 1- 800 - DISCOVER (1.800 -3 - 2683. DISCOVER
DISCOVER I It Pays to AUGU
( .DS C®VER• J Account number ending in 1021
page 2 of 2
Interest Charge Calculation
Your Annual Percentage Rate (APR) is the annu I I interest rate on your account.
Current Billing Period: 8 days
TYPE Of BALANCE ��U jERCENTAGE � ST RAE SU BJECT TO INTEREST CHARGE
Purchases 15.99 V $0 $0
Cash Advances 23.99, 1
0 V $0 SO
V = Variable Rate
Additional Important Information
See your Cardmember Agreement. Your Card ember Agreement contains all the terms of your Account.
Lost or stolen cards. Report immediately) Call - 800. 347 -2683.
What To Do If You Think You Find A lYli take On Your Statement
If you think there is an error on your statement, N frite to us at: Discover. PO Box 30421 Salt Lake City, UT 84130-0421
In your letter, give us the following information:
Account information: Your name and account number
Dollar amount: The dollar amount of fhelsuspected error.
Descri mists lion o ce. f Problem: If you think flier is an error on your bill, describe what you believe is wrong and why you believe
d is a
You must contact us within 60 days after th a error appeared on your statement.
You must notily us of any potential errors ir writing. You m ay call us, but if you do we are not required to investigate any
potential errors and you may have to pay I io amount in question.
While we investigate whether or not there I as been an error. the following are true:
We cannot try to tolled the amount in q iostion, or report you as delinquent on that amount.
• The charge in question may remain on ur statement and we may continue to charge you interest on that amount. But, if
we determine that we made a mistake, u 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 a mour t in question, you are responsible for the remainder of your balance.
• We can apply any unpaid amount agai t your credit limit.
Your Rights If You Are Dissatisfied With Your Credit Card Purchases
If you are dissatisfied with the g oods or 3HViCes that you have purchased with your credit card, and you have tried
in good faith to correct the problem with a merchant, you may have the right not to pay the remaining amount
due on the purchase.
To use this right, oil of the following mustlbe 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 moo 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 h f the purchase. Purchases made with cash advances from on ATM or with a
check that accesses your credit card account do not qualify.
3. You must not yet have fully paid For fh purchase.
If all of the criteria above are mef and are still dissatisfied with the purchase, contact us in writing of:
Discover, PO Box 30945, Salt Lake Ci y, UT 84130-0945
While we investigate, the same rules a )ply to the disputed amount as discussed above. After we finish our
investigation, we will tell you our decis on. At that point, if we think you owe an amount and you do not pay we
may report you as delinquent.
Payments. You may pay all or part of your Ace nt balance at any time. However, you must pay at least the Minimum
Payment Due by the Payment Due Date. Send on yyour payment and the top portion of this statement in the envelope
PProvided. Do not send cash. By sending your ch ck as described above, you authorize us to use information on your check
to make an electronic fund transfer fro your ac unt at the financial institution indicated on your check or to process the
payment as a check transaction. If payment is p essed as an electronic fund transfer, the transfer will be for the amount of
the check. When we use information From your c k to make an electronic fund transfer, funds may be withdrawn from your
account as soon as the some day we receive you payment, and you will not receive your check back from your financial
institution.
The Processing of yyour payment may be delayed f you send cash, correspondence or other items with your payment if if you
send the payment to an other address or if you u e on envelope other than the one provided. Pa t
fx ymen s received m
form at our processing cilily b SPM local time any day will be credited to your Account as of that day. Payments
received at our processing facility after SPM local time wit! be credited to your Account as of the next day. If you have
misp for d laced your envelope, send your I a ent to iscover, PO Box 6103 Carol Stream, IL 60197.6103. Please allow 7.10
elivery. If your payment is refu
days mod un id, we reserve the right to resubmit it as an electronic debit.
I
9721050
NOTICE: SEE REVERSE SIDE FOR IMPORTANT I FORMATION DISCOVER
You can pay your monthly Minimum Payment or a greater amount that does not exceed your current Account balance,
overt a telephone or you can setup automatic yments through a customer service representative by calling
1 800 347 -2683. Automatic payments will c ucted on the Payment Due Date unless you request a recurrin
date (a. y. the 15th day of the month) that occ before your Payment Due Date. If your scheduled 9 Payment
weekend or bank holiday, your payment will rocessed the business day prior to the weekend or b k hot date Inlsordea
to schedule monthly payments b telepphone, will need this statement and your bank account information. You will be
asked to provide the last four (4�digits of the ial security number of the primary borrower. By providing those numbers as
your electronic signature, you will be agreeing this authorization to allow us and your bank to deduct each pa ent you
authorize, in the amount selected by you, from ur bank account. You also authorize us to initiate debit or credit entries to
your bank account, as a icable, to correct a ror in the processing of such payment. You can concel a scheduled
payment by phone at 1-800.347 -2683 or by it at Discover, PO Box 30421 Salt lake City, UT 84 1 30 -042 1 however we
must receive notice at least three business do advance of the scheduled payment. If your payments may vary in amount,
we will fell you on each monthly billing state when your payment will be made and how much it will be. You must ensure
that sufficient funds are available in your bank count, and all transactions must comply with U.S. law.
You can set automatic payments for (i) statem t New Balance, (ii) statement Minimum Payment Due, (iii) ment Minimum
state
Payment Due plus a fixed dollar amount, or (i fixed dollar amount. IF your scheduled fixed payment is not to
the Minimum Payment Due as listed on your m they billing statement, our scheduled
increased to cover the Minimum Payment Due the scheduled payment is renter than the Minimum Payment Due, enough to cover
any
excess will be applied in accordance with yo ardmember A
Balance eement. IF your scheduled payment is greater than the New
�et a o roimt billing statement, that pa ill be processed only for the amount of your New Balance. Your automatic
p
lo Date. y be less than the amount icated on the periodic statement based on credits or payments after the
Closi
If you enroll by phone in our automatic payrn service, please fill -in the following blanks below and retain the authorization
for your records.
Amount: ❑ Full Pay ❑ Min Pay ❑ Min Pay + $ ❑ Fixed Pay$
Bank Routing #: ank Account #:
Frequency: 0
Credit Reporting. We may report information ut your Account to credit bureaus. late payments, missed payments, or D
other defaults on your Account may be rell in your credit reppoorrt1. We normally report the status and payment history of °
your Account to credit reporting agencies month. IF ou be il'eve that our report is inaccurate or incomplete, please write o°
us at the following address: Discover PO B 531 b, W Imington, DE 19850 5316. Please indicate your name, address,
home telephone number and Account number ca
m
Paying krtwis*. We begin to impose interest urges on a transaction fee or interest charge from the day we add it to the nit
daily balance. We continue to impose infer horgas until you pay t ie total amount you owe us. You can avoid paying X
interest on Purchases as described below. H ever, you cannot avoid paying interest on Balance Transfers or Cash
Advances.
How to Avoid P 'n Interest on Purchases " ace Period"
you paid a Now a once on your prewou i ing statement by the Payment Due Date shown on that billin
will not impose interest charges on new e or
current billing are statement. New Purchases are rc lrases g statement, we
that first of a new Purchase paid by the Payment Due Date on your
appear on the current billing statement.
How We A I Pa ants Ma 1m ct Your ce Period
you o not pay your ew a once n a man , t an, depending on the balance to which we apply your payment,
you may not get o grace period on new Purc res.
How We Calculate Interest Charges Daily E ice Method (ircludir9 current transactions): We calculate interest charges
each billing period by first figuring the "daily lance" for each Transaction Category. Transaction Categ include
standard Purchases, standard Cash Advcm nd different promotional balances, such as Balance Transfers.
How We Figure the Daily Balance for Each T sacfion Category
We start with the beginning balance each day. The be
your balance on the Lost day of your inning balance for the first day of the billing period is
evious billing period
We add any interest charges occru n the previous day's daily balance and any new transactions and fees. We
add an new transactions or Fees as the later of the Transaction Date or the first day of the billing period in
which the transaction or fee posted our Account.
We subtract any new credits and ants.
• We make other adjustments (incuudi those adjustments required in the "Paying Interest" section).
How We Figure Your Total Interest Charges
• We multiply the daily balance for Transaction Category by its daily periodic rate. We do this for each day in
the billin period. This gives us the i rest charges for each Transaction Category. To get a daily periodic rata,
we divide the APR that applies to ronsaction Category by 365.
• We add up all the daily interest Cho s. The sum is the total interest charge for the billing period.
Now We Include Fees
We add Balance Transfer Fees to the applic, a Balance Transfer Transaction Category We add Cash Advance
Fees to the applicable Cash Advance Tran ion Category. We add all other fees to the standard Purchase
Transaction Category.
Balance Subject to Interest Rate. Your state nt shows a Balance Subject to Interest Rafe. It shows this for each
transaction category. The Balance Subject nterest Rafe is the average of the daily balances during the billing
period.
Credit Balances. If your Account has a c lance, the amount is shown on the front of your billing statement.
A credit balance is money that is owed to You may make charges against this amount if your Account is
open. d b will send you a refund of any re fining balance of $1.00 or more offer 6 months, or as otherwise
required by applicable low.
For MD (Telecommunications Device for th. ae assistance, please call 1- 800 - 347 -7449.
Disgle ?U nitor and /or record telep a calls between you and Discover representatives for quality assurance
Purposes.
The Discover ® card is issued by Discover B , Member FDIC
RZNFE001
Questions? Visit wwwbiscov .cam or
call 1.800- DISCOVER (1.800 -34 683). DISC
A
VERIFICATION
(Nance) (T�tl )
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 , ) C)
(Sign ture)
DB Servicing Corporation servicing affiliate
For Discover Bank
PO Box 3025
New Albany, OH 43054
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff ,t , n lir ;He FtiOI IChOha r'
Jody SSmith ,��"� ont�5:yv
Chief Deputy 2013 JUN IIt AM 8: 59
Richard W Stewart CUMBERLAND COUNTY
Solicitor PENNSYLVANIA
Discover Bank Case Number
vs. 2013-2859
Augusta R McAlhany
SHERIFF'S RETURN OF SERVICE
06)07/2013 Ronny R Anderson, Sheriff,being duly swam according to law,states he made diligent search and inquiry
for the within named Defendant to wit:Augusta R McXhany, but was unable to locate the Defendant in
his bailiwick. The Sheriff therefore returns the within requested Complaint&Notice as"Not Found'at 408
S. Fayette Street,Apt.2, Shippensburg Township, Shippensburg, PA 17257. Deputies were informed by
the landlord of that address that the defendant moved out at the beginning of June,the Shippensburg
Postmaster confirms that mail is still delivered to the address provided_
SHERIFF COST: $50.60 SO ANSWERS,
June 12, 2013 RONNY R ANDERSON, SHERIFF
WELTMAN,WEINBERG &REIS CO.,L.P.A.
BY: William T Molczan, Esquire Attorney for Plaintiff(s)
I.D.No.47437
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
Phone: 412.434.7955
Fax: 412.434.7959
File#9721050
DISCOVER BANK
Plaintiff
Cumberland County
Court of Common Pleas
vs.
NO. 13-2859 CIVIL 1
AUGUSTA R MCALHANY
r
n
Defendant(s) — "
-G x` d
PRAECIPE TO REINSTATE COMPLAINT ,
TO THE PROTHONOTARY: `4`
cp
Kindly reinstate the Complaint in the above captioned matter.
WELTMAN,WEINBERG&REIS CO., L.P.A.
By 4 ' /11/
William T Mole Esquire
Attorney for Pl intiff
$11.15 PA /MY
IISArl X15
3a(43
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
LEO-OFFICE.
i THE PROTHONO ART
ow of 4iraiifir
71714 APR 2i PPS 3: 03
or ICEOFTN -$4 RFF
CUMBERLAND COUNTY
Discover Bank
vs. Case Number
Augusta R McAlhany 2013 -2859
SHERIFF'S RETURN OF SERVICE
04/14/2014 07:31 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Complaint &
Notice by handing a true copy to a person representing themselves to be Jeremy Jayne, Roommate, who
accepted as "Adult Person in Charge" for Augusta R McAlhany at 157 Faith Circle, North Middleton,
Carlisle, PA 17013.
ka_t_
DAWN KELL, DEPUTY
SHERIFF COST: $55.12 SO ANSWERS,
April 15, 2014 RON R ANDERSON, SHERIFF
(G) CountySuiie Sheriff, Te!eosoft, in.
;L2,.11L,„Li
WELTMAN, WEINBERG & REIS CO., L.P.A:'LJINS
BY: William T. Molczan Attorney for Plaintiff(s)
I.D.No. 47437
436 7th Ave Ste 1400
Pittsburgh, PA 15219
Phone: (412) 434-7955
Fax: (412) 338-7130
File# 9721050 WTM/SJS
Discover Bank, Through Its Servicing Agent
DB Servicing Corporation Cumberland County
Court of Common Pleas
vs.
No.: 13-2859 CIVIL
AUGUSTA R MCALHANY
PRAECIPE TO DISMISS WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Kindly dismiss the above matter without prejudice .
WELTMAN, WEINBERG& REIS CO., L.P.A.
By 4id"' 71)4
William T. Molczan, Esqujrft
Attorney for Plaintiff
11E11 1111111111 1111H1111 11111 11111 11111 1111 1111111111 1111 11111111