HomeMy WebLinkAbout13-4821 30101855 C A Pit SJS
Supreme Ca..>��,t�.,a��enns�Jlvania 111vR#
4 ..� fL
Cout .off Co�nm�V -
Viii_ oar, hde ForProthonotan+ Use Orrl�
;''
C UMBERLANbit COltnty DoaketNo
The hIffirmation collected on rhis form is used solely for covrt administration proposes. This form does not
supplement or replace the filing fling and service ofpleadings or other papers cis required by lam or rules of court.
Commencement of Action:
13 Complaint ❑ Writ of Summons ❑ Petition
E E3 Transfer from Another Jurisdiction Declaration of Takin
DISCOVER BANK
C Lead Plaintiffs Name: Lead Defendant's Name:
T DAVID D CARLIN
0;. Are money damages requested? El Yes ❑ No Dollar Amount Requested: 63 within arbitration limits
N
(check one) 13 outside arbitration limits
A Is this a Class Action Suit? 13 Yes 12 No Is this an MDJ Appeal? E3 Yes Q 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 �jDebt Collection: Credit Card ❑ Board of Assessment
❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections
❑ Nuisance ❑ Dept. of Transportation
S .. ❑ Premises Liability ❑ Statutory Appeal: Other
❑ Product Liability (does not include ❑ Employment Dispute
Mass tort) Discrimination
C' ❑ Slander/Libel/Defamation ❑ Employment Dispute: Other ❑ Zoning Board
T ❑ Other: ❑ Other:
0 13 Other:
N MASS TOR
❑ 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
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,
PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK (��(
Plaintiff No. l �- / "�� �U�•
VS. COMPLAINT IN CIVIL ACTION
DAVID D CARLIN
Defendant(s) FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
James C Warmbrodt, Esquire
PA I.D. #42524
WELTMAN, WEINBERG & REIS
CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434 -7955
WWR #30101855_
1-
�T Q
t2#
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No
DAVID D CARLIN
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
II
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 1832 PINE RD
NEWVILLE, PA 17241
S. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXX1373. On or about November 20, 2010, the
account was transferred to a new credit card bearing account number
XXXXXXXXXXXX2192.
6. Defendant made use of said credit card and has a current balance
due of $6168.28. 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, DAVID D CARLIN, INDIVIDUALLY, in the amount of $6168.28
with interest at the statutory rate of 6% per annum from the date of
judgment and costs.
WELTMAN, WEINBERG & REIS, CO., L.P.A.
James C Wa rodt, Esquire
PA I.D. # "524
WELTMAN, WEINBERG & REIS CO., LPA
1400 KO PE ' S BUILDING
436 S EN , H AVENUE
PITT UR H, PA 15219
(412 4 -7955
New Balance Minimum Payment Due Account Number ending in 2192
$6,168.28 $1,021,00 Enter Amount Enclosed Below
'Payment Due Date $
January 15, 2013 I
Please make check te poyoWe to Discover Cgrpl.
You a overlimit. - Pay the sum of the mo 19
d minimum payment plus the overlimit amount -M
$1,168.28.
DAVID D CARLIN
1832•PINE RD
NEWVILLE PA 17241 -9542
PO BOX 71084
CHARLOTTE NC•28272 -1084
Address, e-mail or telephone changev '
Go to www.D rscoverwm or print change in space above.
00 0 001986 623692 '4915120616828DDDOD000ZO2100
Xe
_-..
Opening Date. November 21, 2012 = Closing Date: Deceinb� 20, 2012 e 1 of 2 '
B A -
Discover More Card Account Summary payment lnfoe mat' oti 'V
New Balance !$6,168.28
Account number endi Minimum Payment Due* e $ 021.00
ng in 2192 ym :\11\8 Paen t Due Date Previous Balance $ 6,038 . 32 Includes mssi due aam""o0hf•o
Payments And Credits 0.00 ` ,.
Purchases' + 0 IMd aymerM Wamay' "''if we d receivac;ur minimum
Balance Transfers , '+ 0.00 p i4 by 19'a date�isted above,,you ec F64 have to pay cr iate
Cash Advances + 0.00 foe of up to $35 aay`ur purchase and balance transfer
Fees Charged + 35.00 APh for new IanuaMjons m be increased up to the Penally
Interest Char d ' + 94.96 o .. of 23 riayyf�e,
New Balance 6,168128 a t � Pie t Womin : If
See interest Charge Calculation section following ' d ° n �, g you make only the minimum '
fpay rent each pelf j 0ou will pay more in interest and it will
transactions for detailed APR information c
" _ . • ts' • take ydU'long�r to Oay off your balance. For example: '
Credit line • °°� $S,aOO
Credit Line Available y +� $0 00 °+ it `'<; '
Cash Advance Credit tine $2,50000 sari'' ° rs:ca_ '' "' Y ^`
8..:.:tr._7i l:'u E p:
Cash Advance Credit Line A z er"44.cl bk $
'
�` X00 Y c d be able to avold�ri es : 4 1s" A I Only the minimum 20 years $16,822 "
nt Information = efaila '
s ��,, ppyme
. If you.would like information abort credit counseling services,
Z7ash kitack Bon us° Anna ry X rith - oall 1. 800.347 -1 121.
�!° A November
Open CashiSk,BA S Bala $' 0.00
Ne ek Boat, s P er i o d e + 0.
Cashbadt Bonus Balance $ 0.00
To leorn more�k�g in awQ1B0OVer 9e1„
I Easy - . � ^ ttact Manage Your Account Online at www.Discover.com
J . Access your aocoBnt securely atwww.Discovercom Access free online tools like Paydown Planner to create a plan
2. Cal 1- 80041ASCOVER (1.800347 -2683) to paydown your balance, securely access statements, pay
Please have yourDEsoaver® card avai labia. bills online and easily track all transactions
3. WrBe.to us at Discover PO Box 309A3,
Salt take City, UT 84130 (Not a payment address) Make your money worth mores++t —And easy ways to ear
For payments,. please send to address on remittance or and redeem cash rewards
Discover, PO Box 6103, Carol Stream, IL 60197.6103 NEWI Access your account securely through your
For TDD (telecommunications Device for the Deal) mobile phone
assistance, please call 1.800347.7A49.
Transactions
Trans. Post
Data Dare
Feei Dee 15 Dec 15 LATE FEE $ 35.00
TOTAL FEES FOR THIS PERIOD 33,00 . -
6darest Charged INTEREST CHARGE ON PURCHASES $ 94.96
30101855 INTEREST CHARGE ON CASH ADVANCES 0,00
INTEREST CHARGE ON BALANCE TRANSFERS. 0,00 E
NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION DISCOVER '
TranSaittianS
. -
(cont.)
bye g
Interest Charged TOTAL INTEREST FOR THIS E° D..,,,,_ ry "` $ 94.96
2012,T�Qs Yearto -Date
TOTAL FEES C .. ARPED IN 266 $ 250.00 '
TOTAL INTERESTtHAR DIN 20t 2 `i 822.44
30/03855
duesfii01W5 ?'Visltwww.Digover.00m 6r
call 1 -800-DISCOVER (1- 800 - 347.2683). DISC AVER'
•tt pot's to DAVID CARLIN
I '
DISCOVER Account number ending in 2192
' page 2 of 2
Interest Charge .Calculation'
Your Anmd Percentage Rate (APR) la the annual interest rate on your account.
Current BAI6rg Period. 30 days
TYPE OF BALANCE ANNUAL PERCENTAGE BALANCE SUBJECT TO INTEREST CHARGE .
RATE (APR) IINT6tEST RATE
Purchases 18.99% .V $6,084,09 $94.96
Cash Advanoes 23.9990 V $0, $
V - Variable Rate
Additional knportaal 6rformati l m
Soe.y" Cardmern6or Agnsemort. Your C:ardmember Agreement contains all the termi of your Account.
Lost or stolen cards. Report immediately! Call 1- 800-347 -2681
What To De If Yes Think Yaa Find A Nifatake On Yosir Awligagat
• U yov think there is on error on ur statement, write to us at: Discover, PO'Box 30421, Salt Lake City, LIT 8 4 1 3 0-042 1.
In your lever,'give us the following information:
Accountinfonjdea: Your name and account number.
PAM a oust The dollar amount of the suspecte l error.
- .If you think there, Ii an error an your bill, describe what you believe is 1 z: ' why you believe
It Is a misia a.
Ybu niust contact us within 60 days after the error ap peared) on your statement.
You -.must notify us of any potential errors (p You m ay call us, but if you do we aSre �)�r to i gale any
potential errors and you may have to pay tfieount in question.
While we Investigate whether or not there has been an error, the following ore true:
We cannot try to collect the amount in question,' or report xou as delinquent on that ait, t
The charge in question may , remain on your statement, and we may continue to charge `yov Interest on chat o oyrit. But, if
we determine that we made a mistake you will not have to pay the amount in question or a. 144real or other fees related
to that amount.
:While you do not have to pay the amount in- question, yav are •reapansi_ ble fo�,lhp�ema�irtde�r o your b6 nce.
We can apply any unpaid amount M91nat youi credit Limit.
tf you are dissatisfied with the `6 or services that you hsnli Nurch`rsed wi ,your credal card, and you have tried
in good Faith to correct the proae:. with the merchant, you may, a fFre right lief 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 made in your me stafe�or wi(hin 100, F.yovr current ailing address, and .
the purchase price'must have bean more th& $5Q. (Note: Neither ot'tliIese die. necessary I� your purchase was
based on an advertisement we mailed'to y'ou or i we a camparry
h thal!so c ld you the goods or cervices.) .
2: You must have used your credit card for the`�urca Pun ha6 wff)i ash advancea From an ATM br with a
check that acoeases your credit card.aeaounf alb not qua �'
3. You must not yet have kk paid +far the purchg�se 'Z
if A of the criteria above arg hiet n 5 'y� u aro still dissatiafl with the purchase, chH
oact us In writ ing at:•
Discover, PO Box 30945, Soft Lak City, 'Ju.T 84 130.8945 ��
While we investigate, 9 same rules�gpply foIthe dtapvle8 a krtt as dimmsod above. After we flnlah ou
investigation, we *Qollvou o8r dectsi "on 1i that point, I�We think you owe an amount and you do'not pay we
may report you as delinquent..
Paymerlts.,You may p ay�dl or ' of yoyrr A Ant balance al any fl e. However, you must pay al least the Minimum
Payment Dub by the Payment D' Dates Send on our iSaymarrt the top portion of this akrtement in the envelope
provided. Do not sendicash. 'B sendmg,y" 49- as described above you authorize us to use information on you check
to make an electronic fur hans�rfro your aocounf'q).the Financial ind(tulion indicated on your check or to process the
Uppaa mment as a check,hansaction. If enl is recessed as an electronic Fund transfer, the transfer will be for the amount of
yy -eheck" V) n we'b infp atior� om y a check to make ari electronic fund transfer, funds coat' ba withdrawn from your'
account as soon a the a dy we r ,eve y r payment, and you will not reeelve your check back from your financial
The pr Tngh�oI yo p�mont may-bo detayod fF you send cash, correspondence or other Items with 'you paymont, If you
send fhe �aym..t airy otfier Address bt"ff you use an envelope other than the one provided. Payments received In proper
Form at ouryxocessir q facility�yy SPM.locol iime on any alpyy will be credited to your Account as of that day. Payments'
received at our pr ing citify afte
n�is r 5PM local time will be credited to your Account as of the next day. If you have -
�ttec� y la se 211 ur At to Discover, PO Box 6103 Card Stream It 60107-6103, 'Please o" 7.10
clays r da very`+lf your' is re road unpaid, we reserve the rig(it to resubmit 403 an electronic debit.
301Q1865 .
NOTICE: SEE REVERSE SIDE -FOR IMPORTANT INFORMATION DISC�V
• ''sGer3 • •
You can your monthly Minimum Payment Due, or a greater amount that does not exceed your current Account balance,'.
over the ekphone or you can setup automatic pa orb tough a customer service to presentaFive by calling '
r - 1- SOD -347 -2683. Automatic payments will be deducted on the, Payment Due Date unless you request a recurring pay�'nenF
date (e .g., the 15th da� duy prior 10 of the month) that occurs before your Payment Due Date. If your sclleduied p paayymr� ent safe k815 on a
weekend or bank oN ay, your payment will be processed the business the weakk' end or bank iw in order
liday. '
to schedule monthly payments b tefephon @, you w!11 need this afatame t and your bank account information. Yau will be
asked to provide Are lost four (4Ndigits pf the social sbcurity number ofPthe primary borrower. By providing those numbers as
your electronic signature, you will be agreeing to this authorization to allow us and your bank to deduct each payment you "
authorize, in the amount selected by you, from your bank account. You also authorize us to initiate deblt or credit entries to
your bank account, as applicable, Fo correct an error in the processing of such payment. -You can cancel a scheduled,
payment. by phone at 1.800,347 - 2683 pr by'mal) of Discover, PO Box 30421, Sale Lake City, UT 84130.0421; however we _.
must receive notice at least three business days in advance of.the scheduled payment. If your payments may vary in amount,.
we will tell you on @ash monthly billing statement when your payment will be made and how much 4 will be, You must ensure, '
that sufficient funds are available in you bank account, and all transactions must comply with U.S. law,
You can set automatic payments for: (1) statement New,Batanco, (it) statement Minlmurr� Payment pus, (il[) staterrlent Minimum
Payment -pus plus o fixed dollar amount, or (iv) *fixed dollar amount. If your scheduled fixed payment is not enoug h to cover
the Minimum Payment Dire as listed on your monthly billfn statement, your scheduled payment lot that month will be '
increased to cover ihe'Mlnimurn Payment Due. If Ax sc heduled payment is grader than the Minimum Payment Due, any
exoesswfll be eat in accordance with your Cordmember Agreement. If your scheduled payment is greater than the New
Balance on you i brTli statement, that payment will be processed on for the ombvnt of yobr New Balance, Your automatic ppaayymment amours may than the amount indicatbd on the periodic statement based on credits or payments after the
Closing Date.
• If you enroll by phone in our automatic payment service, please the following blanks below and r tat" n authorization .
for your records.
I Amount: [I Full Pay ❑ Min Pay ❑ Min Pay+ ❑ Flx ' ,,
uc ay
Bank Routing S ; Bank Account #: Freduelnoy:
Credit ReporRrrg. 1Ne may report information about your Account to credit bureaus. late effts ir' I add payrperds,7s
other dafauka on your Account maybe reflected in yew credit report. We norrnally report f�hedstZIand payment+ istory of
your Account ro credit reporting agencies eadt.mordh. If yyoau lave that our report Is inaccura�a or litcomplefe, pi writ.
us d the following address: piacover, PO Box 15316, Wilmington, DE 19850 5316, Please, indicate your name, address,
., home telephone number and Accoxmt number. . • ,,,,� � � �
Payfirgg'.listerest: We be in to Impose interest charges oil a hansacfian fee o intere charg8i tM..?lay we dd it tb.ihe
" drnly 6alanoe• We continue to Impose interest charges vnfll you pay tFre tofal`amourit Wows C You can avid paying
inferpat on Purchases as described ba ►ow. 'However, you cannot avoid ing'lirferest bn Balan Transfers gr'Cash
Iaw to Avoid CMdrq
' Advance's. • '4. ' .
r 1 u pa 0 Balance on your previous 'ling.atafemer�t lty Pa ant a Dat a�town the bflEing statemerd, we '
wr'li ll imp' oso Interest *barges on new Purchases w a po C n )Pa no Purchase, paid`bj lisp aymant Due Dole on youi
current (tilling atatamarrt. New Purchases are Purc(xaseaiaf on tFecurreilt�biBing`statement.
Reri y
It you o net pay your w Ba once in fu 'sac mart eno e y ndieig on the bake o whtdh we apply your payment,
YOU may not get a grace,poriod on new Purchases.:
How We Calculate Interest Charges - Daily Balaitee liAe9r6d:2@klud g'cunw* 1t rVwctfane): 'We eclwlale interest ehatges
each billing period by first figuring fhe " da)ly balance ". For h Tronsadiop"Calegoty. Transaction Cdegorles Include
standard Purelhasas, standard Cash A�dvan and °differnt pro�,otiondhbalances, such as'Balan�e Transfers.
Few We Figure the Daily Balanas for Eaclr Trmr a on ° togery
We ataft with the i {wia for each d :: The fie inn "irig balmrce far the first day of thebilllng'period is
:! your Wanes thea3i d�ayrof youi'previousfiling period.
We add any ird est charges a nred�dl the previous doyrs daily balance and any new transactions and fees. We
add-any now ;nnsadions cr Jees it,of th `4.Lafer o`f.the Transaction Date or the first day of the billing period In
which Rte transaction 8r., - postedrto your Agmtr�.
+ We'subtrad arty�fow iredits a d paym". 'ke
We mgike o'"iht dl enfs- CrdudiWGd%3! adlu`kments required, in the'" Paying.lnterest "'section).
How We f7lgiirs �r 7 Chargg8 r� �t
Xe mukiply iiy balance for eac0ranwalion Category by its daily periodic'rde,' We do hits for each day in
f T" bill��nnqq ppae Tod V77hk gives the)IMerest charges for each Transaction Category. To got a daily period[* rate,
t� drvkle�M APi�ihat
We c up INAme daily ante s1 charges. The sum Is the total Interest charge far the billing petiod. "
How We hieludo Fses+� . e '
We add Bolance4ronsfer.fees to the applicable Balance Transfer Transoction Category We add Cash Advance
Fees to the apptics' Cash nce Transaction Category'. We add all other fees to iho standard Purchase '
Transaction[ '
Balance Subiio�dt to interest Rate. Your statement shows a Balance Sxiblect to Interest Rate. It shows this for each
transaction category. The Balance Subject to Interest Rate is the average of the daily balances c1dring the billing
period. '
Credk Balances. If your Account has a credit balance, the amount is shown on the frond of ur billing statement.
A credit balance Is money that is owed to you. You may make charges against this arncurr if your Account is
open. We will send you a refund of any remaining balance of $1.00 or more after 6 morifthhs, or-as otherwise
required by applfoabfa law:
ForTDD (telecommunications Device for the Doafj assistance, please eall'1-400-347- 7449..
p D`sco may monitor and /or record telephone oalls between you and Discover represent ss
atives for quality aurance
'the'Discower ®card is issued by Discover Bank, Member FDIC RZNFEDOI
30101855.•
*Q11,11G 1OtiIS? Visit WWWAsmverlcom or
call 1- 800 - DISCOVER (1-800-W-2683) DISCIS VEff - '`
� VERIFICATION
L A (Name) (Titl
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 fluther stated that Discover Bardc 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
4(Siature)
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 F i'O 7 H)O,s, ° ,
Jody S Smith oott,al
13 SEP 23 pm 3 I
Chief Deputy
Richard W Stewart UMEERLA D CL 4+(v
Solicitor .5-EE-t E N S Y LVA N I/A
Discover Bank
vs.
Case Number
David M Carlin 2013-4821
SHERIFF'S RETURN OF SERVICE
09/20/2013 Sheriff Ronny R Anderson, being duly sworn according to law, states he made diligent search and inquiry
for the within named Defendant to wit: David M Carlin, but was unable to locate the Defendant in his
bailiwick. The Sheriff therefore returns the within requested Complaint& Notice as"Not Served"at 1832
Pine Rd., Penn Township, Newville, PA 17241.
Depite several attempts, the paperwork expired prior to being served.
SHERIFF COST: $55.12 SO ANSWERS,
September 20, 2013 RONR ANDERSON, SHERIFF
(c)CountySuite Sheriff,Teleosoft,Inc.
WELTMAN, WEINBERG & REIS CO., L.F.A.
BY: Matthew D. Urban
I.D. No. 90963
436 7th Ave Ste 1400
Pittsburgh, PA 15219
Phone: (412) 434 -7955
Fax: (412) 338 -7130
File # 30101855 MDU/SJS
HE PROTHQNO 'A
AMR -7 PM .I :115
CUMBERLAND COUNTY
PENNSYLVANIA
Attorney for Plaintiff(s)
DISCOVER BANK
vs.
DAVID D CARLIN
Cumberland County
Court of Common Pleas
No.: 13 -4821 CIVIL
PRAECIPE TO DISMISS WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Kindly dismiss the above matter without prejudice .
WELTMAN, WEINBERG & REIS CO., L.P.A.
By
Matthew D. Urban, Esquire
Attorney for Plaintiff
IIIIIII11111111111111 1111111111111111111111111111111111111111111111111