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Home My WebLink About14-5883 r, Supreme Coul t ref 'enns�ivama AllNVR# 30348622 C A Pit SJS Cour }nf Common Pleas ( / • , Y,� Cly 1l COverSheet ForProtho�wtan Use CUMBERLAND,� ;`� ;�j w,� Coun11' Docket No: �f The inforination collected on this form is used solely for court administration purposes. This foi•in does not supplemeiit or replace the filing and sei7,-ice ofpleodiizgs or other papeis as required br lal,,or rules of court. Commencement of Action: S U Complaint ❑ Writ of Summons ❑ Petition E Transfer from Another Jurisdiction Declaration of Taking DISCOVER BANK C Lead Plaintiff's Name: Lead Defendant's Name: T DONALD A BROWN I O Are money damages requested? El Yes ❑ No Dollar Amount Requested: ® within arbitration limits N (check one) [3outside arbitration limits Is this a Class Action Suit? ❑ Yes 13 No Is this an MDJ Appeal? ❑ Yes W No 3A William T. Molczan 47437 Name of Plaintiff/Appellant's Attorney: i ❑ 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 ❑ Intentionaluyer Protection Administrative Agencies 13 Malicious Prosecution Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept.of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other E [3Product Liability(does not include E3Employment Dispute Mass tort) Discrimination C ❑ Slander/Libel/Defamation ❑ Employment Dispute:Other ❑ Zoning Board T ❑ Other: ❑ Other: 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 ❑ 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. NOTICE Pennsylvania Rule of Civil Procedure 205.5.(Cover Sheet) provides, in part: Rule 205.5. Cover Sheet (a)(1) This rule shall apply to all actions governed by the rules of civil procedure except the following: (i) actions pursuant to the Protection from Abuse Act, Rules 1901 et seq. (ii) actions for support,Rules 1910.1 et seq. (iii) actions for custody, partial custody and visitation of minor children, Rules 1915.1 et seq. (iv) actions for divorce or annulment of marriage, Rules 1920.1 et seq. (v) actions in domestic relations generally, including paternity actions, Rules 1930.1 et seq. (vi) voluntary mediation in custody actions,Rules 1940.1 et seq. (2) At the commencement of any action,the party initiating the action shall complete the cover sheet set forth in subdivision(e) and file it with the prothonotary. (b) The prothonotary shall not accept a filing commencing an action without a completed cover sheet. (c) The prothonotary shall assist a party appearing pro se in the completion of the form. (d) A judicial district which has implemented an electronic filing system pursuant to Rule 205.4 and has promulgated those procedures pursuant to Rule 239.9 shall be exempt from the provisions of this rule. (e) The Court Administrator of Pennsylvania, in conjunction with the Civil Procedural Rules Committee, shall design and publish the cover sheet. The latest version of the form shall be published on the website of the Administrative Office of Pennsylvania Courts at www.pacourts.us. $ `r jam; TH i , OCT - CUt'4CE Pt"''C.PiF B 1':I1++� 1. 1t4 t` i i�� IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: 5 �� 3 tvr VS . COMPLAINT IN CIVIL ACTION DONALD A BROWN 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 2500 Pittsburgh PA 15219-1842 (412) 434-7955 FAX: 412-338-7130 30348622 C A Pit SJS Q- �� 6�- 7-1- 7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No DONALD A BROWN 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, 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 ' s account, which is the subject of this litigation. 4 . Defendant is an adult individual (s) residing at 11 COURTNEY DR SHIPPENSBURG, PA 17257 S . Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX2954 . 6 . Defendant made use of said credit card and has a current balance due of $3013 .44 . A copy of Plaintiff ' s Statement is attached hereto, marked as Exhibit 11111 . 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, DONALD A BROWN, individually, in the amount of $3013 .44 and costs. William T. Molcza 47437 WELTMAN, WEINBER REIS CO. , L.P.A. 436 7th Ave Ste 2500 Pittsburgh PA 15219-1842 (412) 434-7955 FAX: 412-338-7130 WWR## 30348622 C A Pit SJS DISC VER Discover More Card Account number ending in 2954 Open Dote:Apr 26,2014-Close Dote:May 25,2014 Cordmember Since 2012 ACCOUNT SUMMARY PAYMENT INFORMATION Page 1 of 4 Previous Balance $2,927.51 New Balance $3,013,44 Payments and Credits — $0.00 Minimum Payment Due $773.00 Purchases + $0.00 Payment Due Date June 20,2014 Balance Transfers + $0.00 •Includes post due amount of: $667.00 Cosh Advances $0.00 Fees Charged + $35.00 Late Payment Warning: If we do not receive your minimum payment by the Interest Charged + $50.93 date listed above,you may have to pay a late fee of up to$35.00 and your New Balance $3,013.44 purchase and balance transfer APRs for new transactions may be increased up to the Penalty APR of 25.99%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 52,500 balance.For example: Credit Line Available s0 � ttptssalte ries d�nnnul:chztrggs o4ivfll,poyoff g A igtiW-1I etic];W Cash Advance Credit Line $300siqg+}ic6r , rideach. HsnThVW Onc� 1O1'�nanff'is' 'Srntjonesfitntal2di. f ;I? Dr3_ slalemenr`; abaut;,>_ af:� Cash Advance Credit Line Available 50 Onlythe minimum me a nt 1 9 ears S5,328 You may be able to ovoid interest on Purchases. If you would like information about credit counseling services,call 1-800-347-112 1. See reverse for details. REWARDS Cashback Bonus® Anniversary Month 505uly J00 Opening Balance S 0.00 Your FICO°Credit Score on 3/19/14. New Cashback Bonus This Period + S 0.00 More at Discover.com/FICO Redeemed This Period —S 0.00 Cashback Bonus Balance $ 0.00 Please make check payable to Discover. You are overlimit. To learn more,log in at Discover.com Pay the sum of the Minimum Payment Due plus the remaining overlimit amount of$513.44. Make Check payable to Discover NOTICE:SEE REVERSE SIDE FOR IMPORTANT INFORMATION Please fold on the perforation below,detach and return with your payment pQ)/mo"f'IVoupot7 0 pay onitttopoytty p 1bRe Account number ending in 2954 Pl psez�5riar�old,cliporsttrpfe< 'bf$C,bVgr'tP?n: 1 :(03472 83? Minimum Payment Due $773.00 il�il�llll�lillilil�li�lllll�ililllil lli�llllll�l�l�il lll�lilli New Balance $3,013.44 Payment Due Date June 20,2014 DONALD A BROWN 11 COURTNEY DR Amount enclosed 5 SHIPPENSBURG PA 17257-8216 PO BOX 71084 f �p[� CHARLOTTE NC 28272-1084 3034862ZInfernef �IIII�I�III�""'1111"111i11I��'SII"ILII�I'�I II'I��'II'I��II' payments must be received by SPhA ET to be credited as of the some day Address,e-mail or telephone changed?Note changes on reverse side 000001986456739147692030134400204130077300 E Hi9lT c . DONALD A BROWN Accouni number ending in 2954 Open Date:Apr 26,2014-Close Date:May 25,2014 Page 2 of 4 Important information You must ensure that sufficient funds are available in your bank account,and See your Cardmember Agreement.Your Cordmember Agreement all transactions must comply with U.S. low. contains oil the terms of your Account. You can 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 on error on your statement,write to us of: Discover,PO amount payment is not enough to cover the Minimum Payment Due as listed Box 30421,Solt Lake City,UT 84130-0421. You must write to us within 60 on your monthly billing statement,your scheduled payment for that month days after the error appeared on your statement. You may call us,but if you will be increased to cover the Minimum Payment Due. If the scheduled do we ore not required to investigate 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 hitps://discover.com/billing6ghis for o 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 of 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 you enroll by phone in our automatic payment service,please fill-in the Due Date.Send only our payment,and the bottom portion of this statement If you n blanks below and retain the authorization for our records. in the enveloppe provided offer affixing postage.Payments sent without proper 9 y postage will be returned to the sender.Do not send cash. If you pay by (]Full Pa check,you authorize us to use information on your check to make on Amount: y El Min Pay ❑Min Pay+ $ electronic fund transfer from your account at the financial institution indicated 0 Other Amount$ Bank Routing#: on your check or topprocess the payment as a check transaction.If a payment is processed as an eledronic fund transfer,the transfer will be for the amount Bonk Account# of the check.When we use information from your check to make on electronic fund transfer,funds may be withdrawn from your account as soon Monthly on the 0 Payment Due Dote 0 Close Date as the some day we receive your payment,and you will not receive yourDay of month(insert date) check back from your financial institution. The processing of your payment may be delayed if you send cosh,corres- Credit Reporting.We may report information about your Account to credit pondence or other items with your payments,if you send the payment to any bureaus.Late payments,missed payments,or other defaults on your Account 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 of 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 this at our processing facility offer 5PM local time will be credited to your Account address:Discover,PO Box 15316,Wilmington,DE 19850-5316.Please as of the next day.If you have misplaced your envelope,send your payment include your name,address,home telephone number and Account number. to Discover,PO Box 6103,Carol Stream,IL 60197.6103.Please ollow 7.10 days for delivery.If your payment is returned unpaid,we reserve the right to Poy'►ng Interest.Your due date is at legsf 25 dogs after the close of each resubmit i1 as on electronic debit,Payments mode online or by phone will be billing period (at least 23 days for billing periods that begin in February).We credited as of the day of receipt if mode by 5 PM Eastern time. will not charge you any interest on Purchases if you pay your entire balance by the due dote each month.We will begin charging interest on of You can pay your monthly Minimum Payment Due,or o greater amount that Advances and Bolonce Transfers as oft the lacer of the Tr0nsaction Date or the does not exceed your current Account balance,over the telephone or you can first day of the billing period in which the transaction posted fo your Account. setup automatic payments through a customer service representative by tolling 1-800-347-2683.Automatic payments for the billing period shown How We Calculate Interest Charges.We Use the Daily Balance Method on your statement will be deducted on the Payment Due Dote shown on that (including current transactions)to calculate the Balance Subject to Interest statement,or the next automatic payment date referred to on your statement, Rote. For more information,please toll us at 1-800-347-2683. unless you request a recurring payment date(e.g.,the 15°'day of the month) that occurs before your Payment Due Date or Close Date.If your scheduled Balance Subject to Interest Rate. Your statement shows a Balance Subject payment date falls on a weekend or bank holiday,your payment will be to Interest Rote. It shows this for each transaction category. The Balance processed the business day prior to the weekend or bank holiday.In order to Subject to Interest Rate is the average of the daily balances during the billing schedule monthly payments by telephone,you will need this statement and period. your bank account information.You will be asked to provide the last four(4) Credit Balances. If your Account has a credit balance,the amount is shown digits of the social security number of the primary borrower.By providing on the front of your billing statement. A credit balance is money that is owed those numbers as your electronic signature,you will be agreeing to this to you. You may make charges against this amount if your Account is open. authorization to allow us and your bank to deduct each payment you We will send you a refund of any remaining balance of$1.00 or more offer authorize,in the amount selected by you,from your bank account.You also 6 months,or as otherwise required by applicable law,or upon request mode authorize us to initiate debit or credit entries to your bank account,as to the address in the Contact Us section on page 3 of your billing statement. applicable,to correct on error in the processing of such payment.You can concel a scheduled payment by phone at 1-800-347-2683 or by mail at Balance Transfers.Balance Transfers are offer@d of our discretion and Discover,PO Box 30421,Solt Lake City,UT 84130-0421;however,we must accrue interest of the standard purchase rate unless we tell you otherwise. receive notice of least three business days in advance of the scheduled Discover may monitor and/or record telephone calls between you and 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 Discover representatives for quality assurance purposes. will be. The Discover®card is issued by Discover Bank,Member FDIC. TL23N 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 3611481622 To make changes to your address, email or telephone number, visit Discover.com Continued an next page DISC VER Discover More Card Account number ending in 2954 Open Date:Apr 26,2014-Close Date:May 25,2014 Poge 3 of 4 CONTACT US __ _. --.......__ ..__... _ ....__.... _. __.... _._....... - __..... __........... ............__............. ........_.. .............___......._.......__ .__....._.........__....�, � R � Mobile Phone � Inquiry � Mail Payments Acce Access your Manage your 1-800-DISCOVER Discover Discover account securely account anytime, (1-800-347-2683) PO Box 30943 PO Box 6103 I at Discover.com anywhere at TDD 1-800-347-7449 Salt Lake City Carol Stream m.Discover.com _ UT 84130 IL 60197-6103 Transactions Trans.Date Post Date Fees May 20 May 20 LATE FEE $ 35.00 TOTAL FEES FOR THIS PERIOD 35.00 Interest Charged INTEREST CHARGE ON PURCHASES $ 50.93 INTEREST CHARGE ON CASH ADVANCES 0.00 INTEREST CHARGE ON BALANCE TRANSFERS 0.00 TOTAL INTEREST FOR THIS PERIOD 50.93. 2014 Totals Year-to-Date TOTAL FEES CHARGED IN 2014 $ 175.00 TOTAL INTEREST CHARGED IN 2014 S .70 -—....—_......—..........._—.....__.......................................__......__................_......---.......__.....---.....—--._...-—......._.....__.............._.._......----.........._..............--.—......_...........-- —..........._._........._—........__............__......... __241 _.. Interest Charge Calculation —...... ....... Your Annual Percentage Rate(APR)is the annual interest rate on your account. Current Billing Period:30 days ANNUAL PERCENTAGE RATE BALANCE SUBJECT TO TYPE OF BALANCE (APR) INTEREST RATE INTEREST CHARGE Purchases 20.99% V $2,952.06 $50.93 Cash Advances 23.99% V $0.00 $0.00 V=Variable Rate Information For You For more information about how interest charges are colculated see your Cardmember Agreement or go to www.discover.com/interestchurges Your FICO'Credit Score is based on data from TransUnion and may be different from other credit scores.Discover and other lenders may use different inputs like a FICO°Credit Score,other credit scores and more information in credit decisions.If you prefer not to receive your FICO'a'Credit Score on your statement, just call us at 1-800-347-3D85. Please give us two billing cycles to process your request. To learn more,visit Discover.com/FICO.Your FICO score is provided for your own non-commercial personal review,use and benefit. FICO is a registered trademark of the Fair Isaac Corporation in the United States and other countries. 30348622 NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION DONALD A BROWN O N Accoun __.............__..........................__._ t number ending in 2954..........................O.pen Dote :Apr 26,2014-Close Date:May 25,2014 Pa e 4 of 4 _. 30348622 VERIFICATION aAJ (Name) l� (Trtl 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, collection of delinquent accounts and other support services. The collection of delinquent accounts includes the right to forward the same to the attorneys and/or collection agencies for collection and to file suit on Discover Bank's behalf. Both DB Servicing Corporation and Discover Bank are wholly owned subsidiaries of Discover Financial Services. Date Signature) /� ,,, `� DONALD A BROWN n1 "`'�F" v DB Servicing Corporation servicing affiliate XXXXXXXXXXXX2954 For Discover Bank WWR# 30348622 C A Pit SJS Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFFS OFFICE OF CUMBERLAND COUNTY Uf THE PRC T HONG I, T _t. 2014 OCT 21 PM 2: 59 CUMBERLAND COUNTY PENNSYLVANIA OFFICEOFTHES R„IFF Discover Bank vs. Donald A Brown Case Number 2014-5883 SHERIFF'S RETURN OF SERVICE 10/13/2014 04:18 PM - Deputy William Cline, being duly sworn according to law, served the requested Complaint & Notice by handing a true copy to a person representing themselves to be Arlene Brown, Wife, who accepted as "Adult Person in Charge” for Donald A Brown at 11 Courtney Dr • -, S•uthampton, Shippensburg, PA 17257. LLIAM CLINE, DEPUTY SHERIFF COST: $50.60 SO ANSWERS, October 15, 2014 RONNS' R ANDERSON, SHERIFF (c) CountySu ,e Sheriff, Teleosoff, Inc. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff . vs. DONALD A BROWN Defendant TO THE PROTHONOTARY: Civil Action No. 14-5883 CIVIL PRAECIPE FOR JUDGMENT BY, CONSENT Kindly enter Judgment against Defendant, DONALD A BROWN, in the amount of $3,013.44 plus costs, based upon.the consent of the parties. CONSENT€;D TO: WELTMAN, WEINBERG & REIS CO., L.P.A. By: Attorney for Plaintiff DONALD A BROWN 11 COURTNEY DR SHIPPENSBURG, PA 172578216 WWR# 30348622 -a - v, mW L- r�-1 r— rso CG c N) —4 w C:0 r • 01 . D'AL fat j2 .2/.S'/ 7/ 1( 1C£... ,LCL . • IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff` vs. Civil Action No 14-5883 CIVIL DONALD A BROWN Defendant STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment in favor of Plaintiff and against the Defendant, DONALD A BROWN, above- named, in the amount of $3,01.3.44 pursuant to the Stipulation of the Parties for Payment and for the Entry of Judgment by Consent, as follows: .1. Defendant admits indebtedness to Plaintiff in the amount of $3,013.44. 2. To secure the repayment of said indebtedness, Defendant agrees that Judgment by Consent will be entered in favor of the Plaintiff and against the Defendant, DONALD A BROWN, in the amount of $3,013.44 plus continuing interest thereon at the statutory rate of 6.000% per annum from the date of judgment, and costs. 3. Defendant shall make an initial payment on November 21, 2014 of $75.00 and subsequent monthly pay=.rents at a rate of $75.00 commencing on December 21, 2014 and each month thereafter until February 21, 2015 at which point the account shall be reviewed for a further suitable payment arrangment. 4. All payments are to be made payable to the order of "DISCOVER BANK" 5. The first payment due under this agreement is to be received at the offices of Weltman, Weinberg & Reis, Co., L.P.A., 436 7th Ave Ste 2500, Pittsburgh, PA 15219. All future payments are to be mailed to the offices of Weltman, Weinberg & Reis, Co., P.O. Box 5430, Cleveland, OH 44101-0430. 6. Time i.s of the essence of this agreement and should the Defendant fails to have in the hands of Plaintiff or Plaintiffs counsel any payment in full within five (5) calendar days of the stated due date, then Plaintiff shall be immediately free to issue Execution as well as pursue all other remedies, in law or in equity, to collect the full balance of the Judgment entered hereunder plus appropriate additional interest and costs. 7. • No act or omission of the Plaintiff, nor of anyone alleged to be acting on its behalf, shall constitute a waiver. estoppel, or any other excuse for non-performance of any duty undertaken by the Defendant in this Stipulation which the parties agree is final dnd complete. 8. Intending to be legally bound, the parties set their hands and seals this a . day of ct,,..v 20 DONALD A. BROWN 11 COURTNEY DR SHIPPENSBURG, PA 172578216 \VELTMAN, WEINBERG & REIS CO., L.P.A. By: Matthew D. Urban, Esquire PA I.D. # 90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 7th Ave Ste 2500 Pittsburgh, PA 15219 WWR# 30348622 A PIT SJS IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. DONALD A BROWN Defendant Civil Action No. 14-5883 CIVIL NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Jud nt was entered against you on (xx) As u fpsit Judgment in the amount of $1013.44 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non -Pros ( ) Confession ( ) Default ( ) Verdict ( ) Arbitration ( ) Award (XX) By Consent Prothonotary DONALD A BROWN 11 COURTNEY DR SHIPPENSBURG, PA 172578216 By: 1 / PROTHONOTARY (OR DEPUTY)