HomeMy WebLinkAbout13-4310 Supr eme Count o Pennsylvania W` 30120033 C A Pit SJS
f
Court of Common Rleas
Clvil`Co
Shea
For Prothono Luse Oil
C UMBERLANI3 " M Docket No:
County
The in/brination collected on this form is used solely for court administration purposes. This for -i" does not
supplement or replace the filing and service of pleadings or other papers as required b law or rules of court.
Commencement of Action:
S 13 Complaint ❑ Writ of Summons ❑ Petition
E Transfer from Another Jurisdiction E3 eclaration of Takin
C DISCOVER BANK
Lead Plaintiff s Name: Lead Defendant's Name:
T KATHY BEX
I
0 Are money damages requested? ® Yes ❑ No Dollar Amount Requested: ® within arbitration limits
N (check one) ❑ outside arbitration limits
A Is this a Class Action Suit? 13 Yes 13 No Is this an NMJ Appeal? 13 Yes ll No
Name of Plaintiff /Appellant's Attorney: William T. Molczan,47437
❑ Check here if you have no attorney (are a Self- Represented [Pro Sel 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 0 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
[3 Product Liability (does not include [3 Employment Dispute
Mass tort) Discrimination
C ❑ Slander/Libel/Defamation ❑ Employment Dispute: Other ❑ Zoning Board
'I' ❑ 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
❑ Partition ❑ Replevin
PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other:
❑ Dental ❑ Other:
❑ Legal
❑ Medical
❑ Other Professional:
Updated 1/1/2011
e
NOTICE
1
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.
L ROTH(
H13 JUL 23 AN 9: 25
"'UMBCRLMNO COUNTY
PENNSYLVANIA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
8- Pla intiff No:
y3ro
VS.
COMPLAINT IN CIVIL ACTION
KATHY BEX
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
30120033 C A Pit SJS
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No
KATHY BEX
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 205 E WINDING HILL RD
MECHANICSBURG, PA 17055
S. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXX2739.
6. Defendant made use of said credit card and has a current balance
due of $2613.95. A copy of Plaintiff's STATEMENT is attached hereto,
marked as Exhibit " 1 " .
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, KATHY BEX, INDIVIDUALLY, in the amount of $2613.95 with
interest at the statutory rate of 6.00 o per annum from date of
judgment and costs.
-
William T. Mo c n,47437
WELTMAN, WEINBZYG & REIS CO., L.P.A.
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
(412) 434 -7955
FAX: 412- 338 -7130
WWR# 30120033 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.
Discover More Card
Account number ending in 2739
Open Dote: Feb 13, 2013• Close Date: Mar 12, 2013
Cordmember Since 2007
Page 1 of 4
ACCOUNT SUMMARY PAYMENT INFORMATION
Previous Balance $2,548.99 New Balance $2,613.95
Payments and Credits — $0.00 Minimum Payment Due $396.00
Purchases + $0.00 Payment Due Date April 7, 2013
Balance Transfers + $0.00 • Includes post due amount of: $345.00
Cash Advances + $0.00
Fees Charged + $35.00 Late Payment Warning: If we do nof'receive yout,minimum payment by the
Interest Charged + $29.96 dote listed above, you may hove -to pay. o _late fee of up to $35.00 and your
New Bolonce $2,613.95 purchase andbolonce transfer, APRs for new fronsactions may be increased up to
the Penalty APR "of 20.24% variable.
See Interest Charge Calculation section following the Minimum Payment Warning: If you make only the minimum payment each
Transactions section for detailed APR information period, you will pay more in interest and it will take you longer to pay off your
Credit Line $2,000 balance. For example:
Credit Line Available $0 t os ng t , Y j y r f
Cosh Advance Credit Line $1,000 yam t istatementin about) ;. _
Cash Advance Credit Line Available $0 On fhe minimum payment 14 ears m �$4 ✓ 881
You may be able to avoid interest on Purchases. If you would like information about credit counseling services, call 1- 800 - 347.1121
See reverse for details.
_j
.REWARDS
Contact Us Discover.com Cashback Bonus® Anniversary Month
1. 800 - 347.2683 August
Opening Balance $ 0.00
See 'Information For You" section for important information New Cashback Bonus This Period + $ 0.00
regarding Your Billing Rights. Redeemed This Period — $ 0.00
Please make check payable to Discover. You are oyerlimit. Cashback Bonus Balance $ 0.00
Pay the sum of the Minimum Payment Dve plus the` To learn more, log in of Discover.com
remaining overlimit amount of $613.95.
Make Check payable to Discover. NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION
Please fold on the perforation below, detach and return with your payment.
tPoryment`Coupon _ ,' a }tay`�h(jr1e!png Account number ending in 2739
1'�ebse do not fold r c�tp'oa.stoPle ISisCO�eoRP 80034726$3, Minimum Payment Due $396.00
IIIII1�111lIIIIIIIII�IIII' IIIII�IIIrIIII�Ir�l�l 'IIIIII��l�rlllld New Balance $2,613.95
Payment Due Date April 7 2013
0 KATHY $
WINDING HILL RD Amount enclosed
MECHANICSBURG PA 17055 -5621
PO BOX 71084
� Q� � � CHARLOTTE NC 28272 -1084
301 2 `rno! and Internet payments must be received by 5PM ET to be credited as of the some day. IIIIIIIIIIIII' II' IIII" II IIIIIIIIII 'lll'IIIIIII)IIIIIIIIIIII'I'I'
Address, e or telephone changed? Note changes on reverse side.
000001986458835829082026139500157500039600 ` EXHIBIT
A .
KATHY BEX Account number ending in 2739 Open Date: Feb 13, 2013 Close Date: Mar 12, 2013 Page 2 of 4
Important Information You must ensure that sufficient funds are available in your bank account, and
See your Cardmember Agreement. Your Cardmember Agreement contains all transactions must comply with U.S. low.
all the terms of your Account.
You con set automatic payments for (i) statement New Balance, (ii) statement
Lost or stolen cards. Report immediately! Call 1- 800 - 347 -2683. Minimum Payment Due, (iii) statement Minimum Payment Due plus a fixed
What To Do If You Think You Find A Mistake On Your Statement dollar amount, or (iv) Other dollar amount. If your scheduled "Other dollar
If you think there is an error on your statement, write to us at: Discover, PO amount" poyment is not enough to cover the Minimum Payment Due as listed
Box 30421, Salt Lake City, UT 84130 -0421 You must write to vs within 60 on your monthly billing statement, your scheduled payment for that month
days after the error oppeo red on your statement. You may call us, but if you will be increased to cover the Minimum Payment Due. If the scheduled
do we are not required to investigote any potential errors, and you may have Payment is greater than the Minimum Payment Due, any excess will be
to pay the amount in question. The Billing Rights Notice further explains your applied in accordance with your Cardmember.Agreement. If your scheduled
rights. Please see your Cardmember Agreement or visit payment is greater than the New Balance on your billing statement, that
https : / /discover.com/billingrights for a copy of this notice. payment will be Processed only for the amount of your New Balance. Your
automatic payment amount may be less than the amount indicated on the
Payments. You may pay all or part of your Account balance at any time. billing statement based on credits or payments`after the Close Date.
However, you must pay of least the Minimum Payment Due by the Payment If ou enroll b hone in our automatic ment service,
Due Date. Send only your payment and the bottom portion of this statement y P Pay lease fill - in the
P
in the envelope provided. Do not send cash. If you pay by check, you fo lowing blanks below and retain the authorization for your records.
authorize us to use information on your check to make on electronic fund Amount: [I Full Pay Min Pay Q Min Pay+ $
transfer from your account at the financial institution indicated on your check
or to process the payment as o check transaction. If a payment is processed Other Amount$ Bonk Routing #:
as on electronic fund transfer, the transfer will be for the amount of the Bank Account #
check. When we use information from your check to make on electronic fund
transfer funds may be withdrawn from your account as soon as the some Monthly on the ❑ Payment Due Dote 0 Close Date
day we receive your Payment, and you will not receive your check back from 0 Day of month (insert date)
your financial institution.
The processing of your payment may be delayed if you send cash, Credit Reporting. We may report information about your Account to credit
correspondence or other items with your payment, if you send the payment to bureaus. Late payments, missed payments, or other defaults on your Account
any other address or if you use an envelope other than the one provided: may be reflected in your credit report. We normally report the status and
Payments received in proper form at our processing facility by 5PM local time Payment history of your Account to credit reporting agencies each month. If
on any day will be credited to your Account as of that day. Payments received you believe, that our report is inaccurate or incomplete, please write us at the
at our processing facility after 5PM local time will be credited to your Account, fallowing odd' row. Discover, PO Box 15316, Wilmington, DE 19850 -5316.
as of the next day. If you have misplaced your envelope send your payment Please include your name, address, home telephone number and Account
to Discover, PO Box 6103, Carol Stream, IL 60197.6103. Please.allow 7.1'0 number.
days for delivery. If your payment is returned unpaid, we reserve the right to
resubmit it as an electronic debit. Payments mode online 'or by phone will be Paying Interest. Your due date is at least 25 days after the close of each
credited as of the day of receipt if made by 5 PM Eastern time. billing period (at least 23 days for billing periods that begin in February). We
will not charge you any interest on Purchases if you pay your entire balance
You can pay your monthly Minimum Payment Due, or a greater amount that by the due date each month. We will begin charging interest on Cash
does not exceed your current Account balance, over the telephone or you can Advances and Balance Transfers as of the later of the Transaction Date or the
setup automatic payments through a customer service representative by first day of the billing period in which the transaction posted to your Account.
calling 1- 800 - 347 -2683. Automatic payments for the.billing period shown
on your statement will be deducted on the Payment Due Date shown on that' How We Calculate Interest Charges. We Use the Doily Balance Method
statement, or the next automatic payment date referred tc on your statement, (including current transactions) to calculate the Balance 5ubl'ect to Interest
unless you request a recurring payment date (e.g , the 15 day,of the -month) Rote. For more information, please call us at 1- 800 - 347 -2683.
that occurs before your Payment Due Date or Close.Date.`If your scheduled
payment date falls on a weekend or bank holiday, your payment will be Balance Subject to Interest Rate. Your statement shows a Balance Subject
processed the business day prior to the weekend or bank holiday. In order to to Interest Rate. It shows this for each transaction category. The Balance
schedule monthly payments by telephone, you will need this statement and Subject to Interest Rate is the average of the daily balances during the billing
your bank account information. You will be asked to provide the last four (4) period.
digits of the social security number of the primary borrower. By providing
those numbers as your electronic signature, you will be agreeing to this Credit Balances. If your Account has a credit balance, the amount is shown
authorization to allow us and your bank to deduct each payment you on the front of your billing statement. A credit balance is money that is owed
authorize, in the amount selected by you, from your bank account. You also to you. You may make charges against this amount if your Account is open.
authorize us to initiate debit or credit entries to your bank account, as We will send you o refund of any remoinin? balance of $1.00 or more after
applicable, to correct on error in the processing of such payment. You can 6 months, or as otherwise required by applicable law, or upon request made
cancel o scheduled payment by phone at 1 -800- 347 -2683 or by moil at to the address in the Contact Us section on page 3 of your billing statement.
Discover, PO Box 30421 Solt Lake City, UT 84130 -0421; however, we must Discover may monitor and /or record telephone calls between you and
receive notice at least three business days in advance of the scheduled Discover representatives for quality assurance purposes.
payment. If your payments may vary in amount, we will tell you on each
monthly billing statement when your payment will be mode and how much it The Discover@ card is issued by Discover Bank, Member FDIC. TL23N
will be.
CHANGE OF ADDRESS
If correct on front, do not use. Please print clearly in blue or black ink, in the space provided.
Street Address Home Phone
Work Phone
City Email
� 0106t3
To make changes to your address, email or telephone number, visit Discover.com
Continued on next page
Discover More Card
Account number ending in 2739
Open Date: Feb 13, 2013 Close Date: Mar 12, 2013
Page 3of4
CONTACT US
A Web ® Mobile O Phone ® Inquiry 0 Mail Payments
Access your u! Manage your 1 •800- DISCOVER Discover Discover
account securely occount anytime, (1- 800 - 347 -2683) PO Box 30943 PO Box 6103
of Discover.com anywhere at TDD 1- 800 - 347 -7449 Soh Lake City Carol Stream
m.Discover.com UT 84130 IL 60197 -6103
Transactions
Trans. Date Post Date
Fees Mar 7 Mar 7 LATE FEE $ 35.00
TOTAL FEES FOR THIS'PERIOD 35.00
Interest Charged INTEREST ON. PURCHASES $ 29.96
INTEREST CHARGE ON CASH ADVANCES 0.00
INTEREST ON BALANCE TRANSFERS 0.00
TOTAL IN, TEREST,,FOR THIS PERIOD 29.96
2013 Totals Year -to -Date
TOTAL FEES CHARGED IN 2013 $ 105.00
TOTAL INTEREST CHARGED IN 2013 $ 93.71
Interest Charge Calculation
Your Annual Percentage Rate (APR) is the annual interest rate on your account.
Current Billing Period: 28 days
ANNUAL PERCENTAGE RATE BALANCE SUBJECT TO
TYPE OF BALANCE (APR) INTEREST RATE INTEREST CHARGE
Purchases 15.24% V $2,563.40 $29.96
Cash Advances 20.9996 $0.00 $0.00
V= Variable Rate
Information For You
Your Billing Rights: Keep This Document For Future Use
This notice tells you about your rights and our responsibilities under the Fair Credit Billing Act.
What To Do If You Find A Mistake On Your Statement
If you think there is on error on your statement, write to us at: Discover,PO Box 30421,Solt 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 the suspected error.
Description of problem If you think there is on 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.
At least 3 business days before an automated payment is scheduled, if you wont to stop payment on the amount you think is wrong.
You must notify us of any potential errors in writing. You may call us, but if you do we ore not required to investigate any potential errors and you may have
to pay the amount in question.
What Will Happen After We Receive Your Letter
When we receive your letter, we must do two things:
1 Within 30 days of receiving your letter, we must tell you that we received your letter. We will also tell you if we have already corrected the error.
2. Within 90 days of receiving your letter, we must either correct the error or explain to you why we believe the bill is correct.
While we investigate whether or not there has been on error:
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.
While you do not have to pay the amount in question, you are responsible for the remainder of your balance.
We con apply any unpaid amount against your credit limit.
30120033
After we finish our investigation, one of two things will happen:
NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION
KATHY BEX Account number ending in 2739 Open Dote: Feb 13, 2013 Close Date: Mar 12, 2013 Page 4 of 4
Information For You Continued
If we mode a mistake You will not have to pay the amount in question or any interest or other fees related to that amount.
If we do not believe there was a mistake You will have to pay the amount in question, along with applicable interest and fees. We will send you a statement
of the amount you owe and the dote payment is due. We may then report you as delinquent if you do not pay the amount we think you owe.
If you receive our explanation but still believe your bill is wrong, you must write to us within 10 days telling us that you still refuse to pay. If you do so, we
cannot report you as delinquent without also reporting that you are questioning your bill. We must tell you the name of anyone'fo whorrm..we reported you as
delinquent, and we must let those organizations know when the matter has been settled between us.
If we do not follow all of the rules above, you do not have to pay the first $50 of the amount you question even if your bill is correct.
Your Rights 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 forth to correct the problem with
the merchant, you may hove 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 hove been mode in your home state or within 100 miles of your'currentmoiling address, and the purchase price must hove been more
than $50. (Note: Neither of these ore necessary if your purchase was based . on on.odvertisement we moiled to you, or if we own the company that sold you
the goods or services.)
2. You must hove used your credit card for the purchase. Purchases made with cosh 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 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 some rules apply to the dispvted 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 moy report you as delinquent.
30120033
VERIFICATION
(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 unsworn 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 Servic s.
Date / (/
(S * gna e / �l
DB vic' orporation servicing affiliate
For Discover Bank
PO Box 3025
New Albany, OH 43054
SHERIFF'S OFFICE OF CUMBERLAND CO_ UNTY
Ronny R Anderson pp r
Sheriff
�,hxti�.4r �4�drun�rr"�^fxtx ,
Jody S Smith " �3 • `"'
Chief Deputy
40 3 � _ t9 WHO: 4
�
Richard W Stewart y
Solicitor 0MCE FT1E�=;NrF P1L:-PMSYLV[AN1A
Discover Bank
vs. Case Number
Kathy Bex 2013-4310
SHERIFF'S RETURN OF SERVICE
07/29/2013 02:31 PM - Deputy Jeff Kolodzi, being duly sworn according to law, served the requested Complaint&
Notice by handing a true copy to a person representing themselves to be Ray Rex, husband,who
accepted as"Adult Person in Charge"for Kathy Bex at 205 E. Winding Hill Road, Upper Allen,
Mechanicsburg, PA 17055.
Szez
J -kdLODZI, DEPUTY
SHERIFF COST: $39.30 SO ANSWERS,
July 30, 2013 RbNW R ANDERSON, SHERIFF
(c)CountySuito Sheriff,Teleosoff.Inc.
•
•
•WELTMAN,WEINBERG & REIS CO.,L.P.A. `(
O .11F PROTHONOTARY
BY: Ashley L. Sweeney, Esquire Attorney for Plaintiff(s)
I.D.No. 313667 2013 OCT -2 AM IQ: 35
436 7th Ave Ste 1400
Pittsburgh, PA 15219 CUMBERLAND COUNTY
Phone: (412) 434-7955 PENNSYLVANIA
Fax: (412) 338-7130
File# 30120033 ASW/SJS
DISCOVER BANK CUMBERLAND County
Court of Common Pleas
vs.
No.: 13-4310 CIVIL
KATHY BEX
PRAECIPE TO DISMISS WITH PREJUDICE
TO THE PROTHONOTARY:
Kindly dismiss the above matter with prejudice .
WELTMAN, WEINBERG&REIS CO., L.P.A.
Ashl?'l Sw:��ey, .'squire
Attorney for Plainti f
I 1111111111111111 III)111111111111111111111111111)11111111 III)1111
•