HomeMy WebLinkAbout13-5827 Supreme Court-.of-,Pennsylvania ,_ WWR# 30180147 C A Pit SJS
Court f Common Pleas
Civil , Cover Sheet ForProtltawtan' Use Only:
C UMBERLAND ,;fu County Docket No: r
o 1 g,
777e information collected on this fibrin is used solely for court administration purposes. This form does not
supplement or replace the filing and service ofpleadings or other papers as required b law or roles of court.
Commencement of Action:
S 12f Complaint ❑ Writ of Summons ❑ Petition
E Transfer from Another Jurisdiction C3 eclaration of Takin
DISCOVER BANK
C
Lead Plaintiff s Name: Lead Defendant's Name:
T KEITH M BARNHART
I
0 Are money damages requested? El 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 AMJ Appeal? ❑ Yes 153 No
A
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 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
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
❑ Partition ❑ Replevin
PROFESSIONAL LIABILITY ❑ Quiet Title ❑ Other:
❑ Dental ❑ Other:
❑ Legal
❑ Medical
❑ Other Professional:
Updated ]/l /2011
THE Pa 1, H Plt't
" TA A
f OCT -- 7 P�, 2:
`qS yLVANLI.4 Y
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff No:
Sga� C v�
vs.
COMPLAINT IN CIVIL ACTION
KEITH M BARNHART
Defendant FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan,47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 7th Ave Ste 1400
Pittsburgh PA 15219 -1827
(412) 434 -7955
FAX: 412- 338 -7130
30180147 C A Pit SJS
S
P -4 aqU sa
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No
KEITH M BARNHART
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 213 E ORANGE ST
SHIPPENSBURG, PA 17257
5. Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXX6628.
6. Defendant made use of said credit card and has a current balance
due of $7799.66. 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, KEITH M BARNHART, INDIVIDUALLY, in the amount of $7799.66
with interest at the statutory rate of 6.00 o per annum from date of
judgment and costs.
William . Molcz ,47437
WELTMAN, WEINBE & REIS CO., L.P.A.
436 7th Ave Ste 1400
Pittsburgh PA 15219 -1827
(412) 434 -7955
FAX: 412- 338 -7130
WWR# 30180147 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 Mnimum Payment Du Account Number ending in 6628
DISCOVER $7,799,66 ,178.00 Enter Amount Enclosed Below
ue Date $ ` 1
October 4, 2011
Please make check payable to Discover Card,
You ore overlimit. Pay the sum of the monthly
minimum payment plus the overlimit amount of
$869.66.
KEITH M BARNHART
732 SOLLENBERGER RD
CHAMBERSBURG PA 17202 -8649
PO BOX 71084
CHARLOTTE NC 28272 -1084
Address, e-mail or telephone change?
Go to www.Discover.com or print change in space above.
000001986455361656376077996600000000117800
Opening Date: August 10, 2011 - Closing Date: September 9, 2011 page 1 of 2
Discover More Card Account Summary Payment Information
New Balance $7,799.66
Minimum Payment Due` $1,178.00
Account number ending in 6628 Payment Due Date October 4, 2011
Previous Balance $7,666.45 •Includes past due amount of $1,022.00
Payments And Credits 0.00
Purchases + 0.00 Late Payment Warning: If we do not receive your minimum
Balance Transfers + 0.00 Payment by the date listed above, you may have to pay a late
Cash Advances + 0,00 fee of up to $35.00 and your purchase and balance transfer
Fees Charged + 35.00 APRs for new transactions may be increased up to the Penalty
Interest Charged + 98.21 APR of 19.99% variable.
New Balance $7,799.66
Minimum Payment Warning: If you make only the minimum
See Interest Charge Calculation section following payment each period, you will pay more in interest and it will
transactions for detailed APR information take you longer to pay off your balance. For example:
Credit Line $6, 930.00 f..aiiia
.Y....:,:.:;;:<.:::., :...,;:.;.,::�.;; >.: >::.. ICY..;,:,::., :.: :.:.3`, ,"..;;•:.:: >•::.:::.:;;:
Credit Line Available $0.00 dditionoixharges }jplpnrg shRwn q3 ujsnying an
Cash Advance Credit Line $3,500.00 ng this card and 17is tn: estimated #otal of
Cash Advance Cr e e $0.00 o ri :s
v e edit Line Available
You may be able to avoid Interest Charges, see Additional Only the minimum 19 years $16,558
Important Information for details. payment
If you would like information about credit counseling services,
Cashback Bonus® Anniversary Month call 1- 800.347.1121.
December
Opening Cashback Bonus Balance $ 0.00
New Cashback Bon T Pe + 0.00
Cashback Bonus Balance $ 0.00
To learn more, log in at wwwMiscoveacom
3 Easy Ways to Contact Us Manage Your Account Online at www.Discover.com
1. Access your account securely at www.Discover.com Access free online tools like Poydown Planner to create a plan
2. Call 1- 800 - DISCOVER [1-80(047-2683) to day down your balance, securely access statements, pay
Please have your Discover® card available. bills online and easily track all transactions
3. Write to us at Discover, PO Box 30943, Make our mono worth moresm —find e ways Self lake City, UT 84130 (Not a payment address) Y Y Y s to earn Y
For payments, please send to address on remittance or and redeem cash rewards
Discover, PO Box 6103, Carol Stream, IL 60197.6103 NEWT Access your account securely through your
For TDD (Telecommunications Device for the Deaf) mobile phone
assistance, please call 1- 800. 347.7449.
Transactions
Trans: Post
Date Date
Fees Sep 4 Sep 4 LATE FEE $ 35.00
TOTAL FEES FOR THIS PERIOD 35.00
InyprpV s18�/ s7 INTEREST CHARGE ON PURCHASES $ 98.21
.S INTEREST CHARGE ON CASH ADVANCES 0.00
INTEREST CHARGE ON BALANCE TRANSFERS 0.00 ,X "Ir71
NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION DISCOVER
Paperless statements mean less clutter, more convenience
Easily access up to 24 months of downloodable, password protected statements.
• See your statement as soon as it's available rather than wait for it to arrive in your mailbox.
• Get helpful payment reminders through e-mail or text messages on your mobile phone.
• Print a paper copy of your statement anytime.
• Sign up today at Discover.com /paperless
02010 Discover Bank, Member FDIC PAPER.0310
Transactions
Trans. Post
(cont.) Date Date
Interest Charged TOTAL INTEREST FOR THIS PERIOD $ 98.21
2011 Totals Year-to -Date
TOTAL FEES CHARGED IN 2011 $ 245.00
TOTAL INTEREST CHARGED IN 2011 765.54
30180147
Questions? Visit www.Discover.com or
call 1 -800- DISCOVER (1 -800 -347- 2683). DISCOVER
KEITH M BARNHART
DISCOVER t DJ COVER Account number ending in 6628
page 2 of 2
Interest Charge Calculation
Your Annual Percentage Rate (APR) is the annual interest rate on your account.
Current Billing Period: 31 days
TYPE OF BALANCE ANNUAL PERCENTAGE BALANCE SUBJECT TO INTEREST CHARGE
RATE (APR) INTEREST RATE
Purchases 14.99% V $7,713.86 $98.21
Cash Advances 23.99% V $0 $0
V = Variable Rate
Additional Important Information
See your Cordmember Agreemem. Your Cardmember Agreement contains all the terms of your Account.
Lost or stolen cards. Report immediately) CAI 1 -800- 347 -2683.
1d11g11y1141f1'py Think You Find Q M_i3t�ke On Yo Sta t9wirm
If you think there is an error on your statement, write 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.
f, Jar amount The dollar amount of the suspected error.
description of Problem: if you think there is an error on your bill, describe what you believe is wrong and why you believe
it is a mista�
You must contact us within 60 days after the error appeared on your statement.
You must notify us of any potential errors in writing You may call us, but if you do we are not required to investigate any
potential errors and you may hove to pay the amount in question.
While we investigate whether or not there has been an error, the following are true:
We cannot try to collect the amount in question, or report you as delinquent on that amount.
The charge in question may remain on your statement, and we may continue to charge you interest on that amount. But, if
we determine that we made a mistake, you will not have to pay the amount in question or any interest or other fees related
to that amount.
While you do not have to pay the amount in question, you are responsible for the remainder of your balance.
We can apply any unpaid amount against your credit limit.
Your Rights If You Are Dissatisfied loth Your Credit Card Purchases
If you are dissatisfied with the goods or services that you have purchased with your credit card, and you have tried
in good faith to correct the problem with the merchant, you may have the right not to pay the remaining amount
due on the purchase.
To use this right, all of the following must be true:
1. The purchase must have been 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 you , or if we own the company that sold you the goods or services.)
2. You must have used your credit card for the purchase. Purchases made with cash advances from an ATM or with a
check that accesses your credit card account do not qualify.
3. You must not yet have fully paid for the purchase.
If ail of the criteria above ore met and you are still dissatisfied with the purchase, contact us in w riting at:
Discover, PO Box 30945, Salt Lake City, UT 84130-09A5
While we investigate, the same rules apply to the disputed amount as discussed above. After we finish our
investigation, we will tell you our decision. At that point, if we think you owe an amount and you do not pay we
may report you as delinquent.
Payments. You may pay all or part of your Account balance at any time. However, you must pay at least the Minimum
Payment Due by the Payment Due Dote. Send only your payment and the top portion of this statement in the envelope
prided. Do not send cosh. B sending your check as described above, you authorize us to use information on your check
to ma an electronic fund transfer from your account at the financial institution indicated on your check or to process the
payment as a check transaction. If payment is processed as an electronic fund transfer, the transfer will be for the amount of
the check. When we use information from your check to make an electronic fund transfer, funds maybe withdrawn from your
account as soon as the same day we receive your payment, and you will not receive your check back from your financial
institution.
The processing of your payment may be delayed if you send cash, correspondence or other items with your payment, if you
send the payment to an other address or if you use an envelope other than the one provided. Payments received in proper
form at our processing facility by 5PM local time on any day will be credited to your Account as of that day. Payments
received at our processing facility after 5PM local time will be credited to your Account as of the next day. If you have
misplaced your envelope, send your payment to Discover, PO Box 6103 Carol Stream, IL 60197-6103. Please allow 7 -10
days for delivery. If your payment is returned unpaid, we reserve the rigk to resubmit it as an electronic debit.
30180147
NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION DISC
You can pay your monthly Minimum Payment Due, or a greater amount that does not exceed your current Account balance,
over the telephone or you can setup automatic payments through a customer service representative by calling
1. 800. 347.2683. Automatic payments will be deducted on the Payment Due Date unless you request a recurring I a ent
date (e.g. the 15th do of the month) that occurs before your Payment Due Date. If your scheduled payment date falls on a
weekend or bank holiday, your payment will be processed the business day prior to the weekend or bank holiday. In order
to schedule monthly payments b telephone, you will need this statement and your bank account information. You will be
asked to provide the last four (4�digi s e agreeinof the social security number of the primary borrower. By providing those numbers as
your electronic signature, you will bg to this authorization to allow us and your bank to deduct each pa ent you
authorize, in the amount selected by you, from your bank account. You also authorize us to initiate debit or credit entries to
your bank account, as opplivable, o coned an ercor in the processing of such payment. You can cancel a scheduled
payment by phone at 1. 800 347 -2683 or by mail at Discover PO Box 30421, Salt Lake City, UT 84 130-042 1; 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 each monthly billing statement when your payment will be made and how much it will be. You must ensure
that sufficient funds are available in your bank account, and all transactions must comply with U.S. law.
You can set automatic payments for: (t) statement New Balance, (ii) statement Minimum Payment Due, (iii) statement Minimum
Payment Due plus a fixed dollar amount, or (iv) a fixed dollar amount. If your scheduled fixed payment is not enouggh to cover
the Minimum Payment Due as listed on your monthly billing statement, your scheduled payment for that month will be
increased to cover the Minimum Payment Due. If the scheduled payment 1s greater than the Minimum Payment Due, any
excess will be applied in accordance with your Cardmember Agreement. Ifyour scheduled payment is greater than the New
Balance on your billing statement, that payment will be processed only for the amount of your N ow Balance. Your automatic
payment amount may be less than the amount indicated on the periodic statement based on credits or payments after the
Closing Date.
If you enroll by phone in our automatic payment 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 #: ; Bank Account #: ;Frequency:
Credit Reporting. We may report information about your Account to credit bureaus. Late payments, missed payments, or
other defaults on your Account may be reflected in your credit report. We normally report the status and payment history of
your Account to credit reporting agencies each month. If you believe that our report is inaccurate or incomplete, please write
us at the following address: Discover, PO Box 15316, Wilmington, DE 19850.5316. Please indicate your name, address,
home telephone number and Account number.
P Interest: We begin to impose interest charges on a transaction fee or interest charge from the day we add it to the
do lonce. We continue to impose interest charges until you pay t6 total amount you owe us. You can avoid paying
interest on Purchases as described below. However, you cannot avoid paying interest on Balance Transfers or Cash
Advances.
�o Avoid Pc in erest on ;lases (" ace Period "1
I you paid the
_ ew - Balance on your previous illib ng statement by the Payment Due Date shown on that billing statement, we
will not impose interest charges on new Purchases or any portion of o new Purchase, paid by the Payment Due Date on your
current billing statement. New Purchases are Purchases that first appear on the currenf billing statement.
How We Apply Payments May I�tlpact Your G
If you do not pay your New Balance in Full eac mont , t en, depending on the balance to which we apply your payment,
you may not get a grace period on new Purchases.
How We Calculate Interest Charges - Daily Balance Method (including current transactions): We calculate interest charges
each billing period by first figuring the "daily balance" For each Transaction Category. Transaction Categories include
standard Purchases, standard Cash Advances and different promotional balances, such as Balance Transfers.
How We Figure the Daily Balance for Each Transaction Category
We start with the beginning balance for each day. The beginning balance for the first day of the billing period is
your balance on the last day of your previous billing period
We add any interest charges accrued on the previous day's daily balance and any new transactions and fees. We
add any new transactions or fees as of the later of the Transaction Date or the first day of the billing period in
which the transaction or fee posted to your Account.
We subtract any new credits and payments.
We make other adjustments (including those adjustments required in the "Paying Interest" section).
Now We Figure Your Total Interest Charges
We multiply the daily balance for each Transaction Category by its daily periodic rate. We do this For each day in
the billing period. This gives us the interest charges for each Transaction Category. To get a daily periodic rate,
we divide the APR that applies to the Transaction Category by 365.
We add up all the daily interest charges. The sum is the total interest charge for the billing period.
Now We Include Foes
We add Balance Transfer Fees to the applicable Balance Transfer Transaction Cotegory We add Cosh Advance
Fees to the applicable Cash Advance Transaction Category. We add all other fees to the standard Purchase
Transaction Category.
balance Subject to Interest Rate. Your statement shows a Balance Subject to Interest Rate. It shows this for each
transaction category. The Balance Subject to Interest Rate is the average of the daily balances during the billing
period.
Credit Balances. If your Account has a credit balance, the amount is shown on the front of your billing statement.
A credit balance is money that is owed to you. You may make charges against this amount if your Account is
open. We will send you a refund of any remaining balance of $1.00 or more offer 6 months, or as otherwise
required by applicable low.
For TDD (Telecommunications Device for the Deaf) assistance, please call 1- 800.347 -7449.
Discover may monitor and /or record telephone calls between you and Discover representatives for quality assurance
purposes.
The Discover ® card is issued by Discover Bank, Member FDIC RZNFE001
30180147
Questions? Visit www.Discover.com or DISCOVER
call 1- 800 - DISCOVER (1- 800 - 347 - 2683).
VERIFICATION
(Name) (Titre)
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 Services.
Date
9�a 5hs JJVIIA ,
(Si tune)
DB Servicing Corporation servicing affiliate
For Discover Bank
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson L
Sheriff '
, � at out+6 114 t
Jody S Smith 1 [ I i ? Ail Deputy l ir
Richard W Stewart " "�11"1E l' 3 t
Solicitor oFFI EoFTFa sFER1FF PEN S+Y!WAWA
15 Yt'1��1-:
Discover Bank
vs. Case Number
Keith M Barnhart 2013-5827
SHERIFF'S RETURN OF SERVICE
10/15/2013 02:47 PM- Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint&
Notice by"personally" handing a true copy to a person representing themselves to be the Defendant, to
wit: Keith M Barnhart at 213 E. Orange Street, Shippensburg Borough, Shippensburg, PA 17257.
JASON'KINSeER, I EPUTY
SHERIFF COST: $50.60 SO ANSWERS,
93. .avi:f
October 16, 2013 RONIV ANDERSON, SHERIFF
(c)Cou-tyauite Sheriff inc.
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson ta,ni C.aurrt+ r���k
Sheriff
z
Jody S Smith Richard W Stewart
Chief Deputy oP .cE",AF T r st<FR FF Solicitor
Discover Bank
vs.
Case Number
Keith M Barnhart 2013-5827
SERVICE COVER SHEET
O
N g
tia Category: Civil Action Complaint& Notice Zone:
X Manner: Adult in Charge Expires: 111111111111111111 Warrant:
Notes: .. . .. �:..
z
C9
0
0
m See -e T� i - ,... '�h., :1 3 ....,d��a �� 0:41., ' € '3 1 e
m Name: Keith M Barnhart Mobile:
Barnhart
z Primary 213 E. Orange Street Notes:
ILI a Address: Shippensburg Borough
a_ Shippensburg, PA 17257
= Phone: DOB:
w Alternate Notes:
re Address:
N
w Phone:
_.. _......
g Alternate Notes:
O Address:
ui
2 Phone:
... �
Name: °Weltman, Weinberg &Reis Co. LP Phone:
M Se a After i 3
O • e
N Date: }C)-y' 3
Time: 1 .21a a 3
Mileage: `7
Deputy:
w Note ]5pitra5IdnsK ... � x.
F 5ei . v -
re
/0(b7/3 / 7
re
I ,,.
r � { I A, '
1 O:i10
L:3 NOV 1 2 PH (: L 5
MBERLAND COUNT
WELTMAN,WEINBERG & REIS CO.,L.P.APEHNSYLVAN1A
BY: Ashley L. Sweeney Attorney for Plaintiff(s)
I.D. No. 313667
436 7th Ave Ste 1400
Pittsburgh, PA 15219
Phone: (412) 434-7955
Fax: (412) 338-7130
File # 30180147 ASW/SJS
DISCOVER BANK Cumberland County
Court of Common Pleas
vs.
No.: 13-5827 CIVIL
KEITH M BARNHART
PRAECIPE TO DISMISS WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Kindly dismiss the above matter without prejudice .
WELTMAN, WEINBERG& REIS CO., L.P.A.
By at-6, , /�
Ashl �w l ey, 'squire
Attorney for Plainti'
11111111111111111 III!111111111111111111111111111111111111