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HomeMy WebLinkAbout05-6072IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. APRIL DELLINGER Defendant No: (),5- 1, 072 ? COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 04642072 C A Pit WLG IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No 0,5--1,O'7-L APRIL DELLINGER 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, is a corporation with offices at 3311 MILL MEADOW DR. HILLIARD , OH 43026 2. Defendant is adult individual(s) residing at the address listed below: APRIL DELLINGER 1181 KINGSLEY RD CAMP HILL, PA 17011 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011298601023025 . A copy of Plaintiff's Statement of Account s attached hereto, marked as Exhibit "A" and made a part hereof. 4. Defendant made use of said credit card and currently has a balance due and owing to Plaintiff, as of November 08, 2005 , in the amount of $7267.83 . 5. Defendant is in default by failing to make payments when due. 6. Plaintiff avers that the Agreement between the parties provides that Defendant will pay Plaintiff's attorneys' fees. 7. Plaintiff avers that such attorneys' fees will amount to $1000.00 8. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for Judgment in its favor and against Defendant , APRIL DELLINGER INDIVIDUALLY , in the amount of $7267.83 with interest at the legal rate of 6.000°% per annum from date of judgment plus attorneys' fees of $1000.00 , and costs. i T2 rodt,42524 ERG & REIS CO., L.P.A. enue, Suite 2718 15219 130 it WLG 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. Vr?bxwY? Ln a4?m.w ayu 11.4, enter amount enclosee tlelow CARD P paymentduedale rl J October 26, 2005 Please make check payable Discover Platinum Card. You are ls Pay the sum of monthly minimum payment ent plus the overlimit amount of $1,267.83. 27 SDSN6A01 0008196 APRIL DELLINGER Consolidate bills quickly and securely with a Balance Transfer to your Discover 1181 KINGSLEY RD Card - Call 1-877-353-0986 TODAY! CAMP HILL PA 17011-6113 Address or telephone change? Please print change in the space above, or go to Discovercard.com. PO BOX 15251 IIIrrJlrrrlrLllrrJtrrlll WILMINGTON DE 19886-5251 1...111.11 lttlrirrlrtll„rlrfrn AIIA" III %IIlIII IIII I l 000006011298601023025072678300000000101742 Discover Platinum Card Account Summary account number 6011 2986 0102 3025 payment due date October 26, 2005 minimum payment due $1,017.42 credit limit $6,000 credit available $0 cash credit limit $600.00 cash credit available $0.00 = $7,267.83 You may be able to avoid Periodic Finance Charges, see the reverse side for details. Cashback Bonus® Closing Date: September 27, 2005 page 1 of 1 previous balance $7,033.86 payments and credits - 0.00 purchases + 74.00 cash advances + 0.00 balance transfers + 0.00 FINANCE CHARGES + 159.97 new balance Cashback Bonus® Anniversary Date: September 27 Previous Cashback Bonus Award Balance $ 0.00 Purchase Award This Period + 0.00 1131' FI Cashck edeRedem Bonus Award Total mpti dons This Period fl 0.00 0.00 T Cashback Bonus Award Balance 0.00 Award Available to Redeem $ 0.00 ransactions trans. Post date date ptherlMlscellaneous Sep 26 Sep 26 LATE FEE $ 39.00 Sep27 Sep27 OVERLIMITFEE 35.00 """' ATTENTION """' ATTENTION """` ATTENTION """' ATTENTION `°"" ATTENTION Your account is seriously past due. Payment of the amount due and arrangements for future payments should be made immediately. Nominal Transaction Average Daily ANNUAL ANNUAL Periodic Fee Daily Periodic PERCENTAGE PERCENTAGE FINANCE FINANCE Balances Rates RATES RATES CHARGES CHARGES current billing period: 31 days Purchases $7110.96 007258% 26.49% V 26.49% $159.97 none Cash Advances $0 0.07258% 26.4991. V 26.49% $0 $0 The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above. Questions? Call 1-800-DISCOVER (1-000-347-2883) or log on to Discovercard.com. For TDO (Telecommunication Device for the Deaf) assistance, see reverse side. Send billing error notice to: Discover Platinum; P.D. Box 15192; Wilmington, DE 19850-5192. Verification The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating To unsworn falsifications to authorities, that he/she is Robert Adkins Accounts Manger of Discover Bank, Plaintiff herein, that he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief. Vkdn: e 6 Signature WWR# ^C ??? c r w C -% CV_ SHERIFF'S RETURN - REGULAR CASE NO: 2005-06072 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS DELLINGER APRIL KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon DELLINGER APRIL the DEFENDANT , at 1901:00 HOURS, on the 2nd day of December , 2005 at 1181 KINGSLEY ROAD CAMP HILL, PA 17011 by handing to APRIL DELLINGER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 15.36 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 43.36 12/05/2005 WELTMAN WEINBERG REIS Sworn and Subscribed to before By: O H me this lqt day of p ty e A.D. ono ry IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. APRIL DELLINGER Defendant No. 05-6072-CIVIL PRAECIPE FOR DEFAULT JUDGMEN"F FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOLCZAN, ESQUIRE PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W W R#04642072 Judgment Amount S 8267.83 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. APRIL, DELLINGER Defendant TO THE PROTHONOTARY: Civil Action No. 05-6072-CIVIL PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, APRIL DELLINGER above named, in the default of an Answer, in the amount of $8267.83 computed as follows: Amount claimed in Complaint $7267.83 Interest from date of judgment at the legal interest rate of 6% per annum Attorney's fees $1000.00 TOTAL $8267.83 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By. WILLIAM T. MOLCZ , ESQUIRE PA I.D.447437 Wellman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04642072 Plaintiff s address is: c/o Wellman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`t' Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 1181 KINGSLEY RD CAMP HILL,PA 17011 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 05-6072-CIVIL APRIL DELLINGER Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judgment was entered against you on, ?jt D0('- (xx) Assumpsit Judgment in the amount of $8267.83 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 (rx) Default Verdict ( ) Arbitration Award Prothonotary By: _ PROT OTARY / APRIL. DELLINGER 1181 KINGSLEY RD CAMP HILL,PA 17011 Plaintiffs address is: c/o Welnman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7°i Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. APRIL, DELLINGER Defendant Case no: 05-6072-CIVIL NON-MILITARY AFFIDAVIT The undersigned, who first being duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. § 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, APRIL DELLINGER is not in the military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the Defendant, APRIL DELLINGER is not in the military service. Further Affiant sayeth naught. A PANT Z SWO TO DS CRl E in,my presence this)??day of NOTARY PUBLIC 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. Request for Military Status Department of Defense Manpower Data Center Military Status Report .° Pursuant to the Service Members' Civil Relief Act Page 1 of 1 JAN-10-2006 12:44:38 4- Last Name First/Middle Begin Date Active Duty Status Service/Agency DELLINGER Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, the above is the current status of the individual, per the Information provided, as to all branches of the Military. 0 Robert J. Brandewie, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Service Members Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are most strongly encouraged to contact us by phone at (703-696-6762). We will then conduct further research. Your failure to re-contact DMDC may cause provisions of the SCRA to be invoked against you. This response reflects current active duty status only. For historical information, please contact the military services SCRA point of contact. See: llttp://'www.defenselink.tni1/faq/pis/PC09SLDR.htn 1. Report !D: BYDRXFUZS/F https://www.dmde.osd.mil/scra/owa/scra.prc_Select 1/10/2006 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK ?? (\ Plaintiff Case # ?`?UC)?? ?1b1` APRIL DELLINGER Defendant(s) IMPORTANT NOTICE TO: APRIL DELLINGER 1181 KINGSLEY RD CAMP HILL,PA 17011 Date of Notice: WWR#: 04642072 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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 / i ? U JAMES MBRODT, ESQUIRE BY PA I. #42524 WELT , WEINBERG & REIS CO., L.P.A. 271OPPERS BLDG, 436 7TH AVE. PIT BURGH, PA 15219 w P-? r r r. -(i d ?-1 . r q0' IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. APRIL DELLINGER Defendant MEMBERS FIRST FCU, Garnishee, +: AP?. L K'".? s (ey R,??(l 1131 CuMP }{;ll, P?+ . ??o? t No. 05-6072-CIVIL PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04642072 3.S"i 2 /n&rke-t Sfre , 7011 .I -aw IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 05-6072-CIVIL APRIL DELLINGER Defendant MEMBERS FIRST FCU, Garnishee TO THE PROTHONOTARY: PRAECIPE FOR WRIT OF EXECUTION Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of Cumberland County: 2. against April Dellinger, Defendant 3. against Members First FCU, Garnishee 4. Judgment Amount $ 8,267.83 Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): $ 327.54 $ $ 8,595.37 WELTMAN, WEINBERG & REIS CO., L.P.A. By: William f"Molcz?n, Es ire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04642072 a. t 01J t' a ,mss e C 6" ?I ?Q ?c I I L , ` C --; ' N) Ara > - C w WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) .? COUNTY OF CUMBERLAND) NO 05-6072 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From APRIL DELLINGER, 1181 KINGSLEY ROAD, CAMP HILL, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of MEMBERS FIRST FCU, 3512 MARKET STREET, CAMP HILL, PA 17011 GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof, (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $8,267.83 Interest $327.54 Atty's Comm % Atty Paid $125.86 Plaintiff Paid Date: OCTOBER 25, 2006 (Seal) L.L. $.50 Due Prothy $1.00 Other Costs * ? ea ?- Curds R. Long, Px tlionota By: REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Deputy Supreme Court ID No. 47437 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 05-6072-CIVIL VS. ph5/? INTERROGATORIES IN ATTACHMENT MEMBERS FIRST FCU APRIL DELLINGER Defendant and MEMBERS FIRST FCU Garnishee FILED ON BEHALF OF: Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR#04642072 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. APRIL DELLINGER Defendant and MEMBERS FIRST FCU Garnishee Civil Action No.: 05-6072-CIVIL TO: MEMBERS FIRST FCU Suggested Reference No.: XXX-XX-3738 3512 MARKET ST., RE : APRIL DELLINGER CAMP HILL, PA. 17011 1181 KINGSLEY RD., CAMP HILL,PA 17011 IMPORTANT NOTICES TO GARNISHEE! A. You are required to file answers to the following interrogatories within twenty (20) days after service upon you. Failure to do so may result in Judgment against you. B. Herein, the word "defendant" means any one or more of the defendants against whom the writ of Execution is issued. C. While service of Writ upon the Garnishee attaches all property of the Defendant subject to attachment which is then in the hands of the garnishee, it also attaches all property of the defendant which comes into the Garnishee's possession thereafter, until Judgment is entered against the Garnishee. For example, the resultant liability of a Garnishee-Bank would not be measured by the balance in the debtor's account, either at the time of service of the Writ or at the time of Judgment against the Garnishee, but rather by the amounts deposited and withdrawn during the intervening period. INTERROGATORIES IN ATTACHMENT 1. At the time you were served or at any subsequent time did you owe the defendant any money or were you liable to him on any negotiable or other written instrument, or did he claim that you owed him any money or were liable to him for any reason? 2. If the answer to Interrogatory 1 is in the affirmative, state the following: the amount of money you owe or owed to defendant, and, if such money is in the form of a fund, the present location thereof; the terms, face amount and amount you owe or owed to defendant on each of such negotiable or other written instruments and the present location of each of such instruments; the amount or amounts that defendant claims or claimed that you owe or owed to him; and the nature and amount of each of such liabilities. saJ - ? Gol lags uv less L\ ? ? 2-)? 3. At the time you were served or at any subsequent time was there in your possession, custody or control of yourself and one or more other persons any property of any nature owned solely or in part by the defendant. 4. If the answer to Interrogatory 3 is in the affirmative, describe the nature, fair market value, and present location of each of such properties. ?011 5. At the time you were served or at any subsequent time did you hold legal title to any property of any nature owned solely or part by the defendant or in which defendant held or claimed any interest? Ok 6. If the answer to Interrogatory 5 is in the affirmative, describe the nature, fair market value, and present location of each of said properties. 7. At the time you were served or at any subsequent time did you hold as fiduciary any property in which the defendant had an interest? 0\?' 8. If the answer to Interrogatory 7 is in the affirmative, describe the nature, fair market value, and present location of each of such properties. 9. At any time before or after you were served, did the defendant transfer or deliver any property to you or to any person or place pursuant to your directions or consent and if so what was the consideration thereof? 10. If the answer to Interrogatory 9 is in the affirmative, describe the nature, fair market value, and present location of each of such properties. a\? 11. At any time after you were served did you pay, transfer, or deliver any money or property to the defendant or to any person or place pursuant to his direction or otherwise discharge any claim of the defendant against you? 12. If the answer to Interrogatory 11 is in the affirmative, describe the amount or nature, fair market value and present location of each of such payments and properties. 10- WELTMAN, WEINBERG & REIS CO., L.P.A. By: 14 4 Imo- '' William olczan, Esqui PA I.D. #47437 WELTMAN, WEINBE G & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR#04642072 ?'? C?' ? ? ;? -T7 "-. tc{ - . ? -?; fT' ?? (.? ?i_ ?-? ) -' r ..`.S tn? ` . 1 tJ SHERIFF'S RETURN - GARNISHEE CASE NO: 2005-06072 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND DISCOVER BANK VS DELLINGER APRIL And now CPL. TIMOTHY REITZ ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0012:34 Hours, on the 7th day of November-, 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT DELLINGER APRIL hands, possession, or control of the within named Garnishee MEMBERS FIRST FCU 3512 MARKET ST . in the CAMP HILL, PA 17011 Cumberland County, Pennsylvania, by handing to RICHARD STARTZERL (ADULT IN CHARGE) personally three copies of interogatories together with 3 true and attested copies of the within WRIT OF EXECUTION and made the contents there of known to His . Sheriff's Costs: So answer Docketing .00 Service .00 Affidavit .00 R. Thomas Kli e Surcharge .00 Sheriff of Cumberland County .00 OOL.1 /l/it, 11/ 8/2006 Sworn and Subscribed to before me this day of By De ut Sheri A.D w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. APRIL DEL_LINGER Defendant No.: 05-6072-CIVIL PRAECIPE TO SETTLE, DISCONTINUE & END AS TO THE GARNISHEE MEMBERS FIRST FEDERAL CREDIT UNION ONLY MEMBERS FIRST FEDERAL CREDIT UNION Garnishee FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA I.D #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR#04642072 - d y IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. APRIL DELLINGER Defendant MEMBERS FIRST FEDERAL CREDIT UNION Garnishee Civil Action No.: 05-6072-CIVIL PRAECIPE TO SETTLE DISCONTINUE AND END AS TO THE GARNISHEE, MEMBERS FIRST FEDERAL CREDIT UNION. ONLY TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue and End the above captioned matter as to Garnishee, MEMBERS FIRST FEDERAL CREDIT UNION, only, upon the records of the Court and mark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C, r brodt PA I.D # 2524 WELT AN, EINBERG &REIS CO., I.-P.A. 2718 opper uilding 436 venth venue Pitts urgh, A 15219 (41 ) 43 955 2072 Sworn to and subscribed Before me the ? 5?h Day of DECEMBER 2006 NO RY PUB COMMONWEALTH OF PENNSYLVANIA Nota ai Saal FWayne A..icr ie ^ , (votary public Of PittabU01 % A ;,--rjheny County MMisslon Expir©sJune29,2010 Member. Pennsylvania,Assoc+a.'.i0r.. of Notaries jJ `b uj R. Thomas Kline, Sheriff, who being duly sworn according to law, states this Writ is returned ABANDONED, no action taken in six months. Sheriff s Costs: Advance Costs: 150.00 Sheriff's Costs 93.54 Docketing 18.00 56.46 Poundage 1.84 Advertising Law Library .50 Prothonotary 1.00 Refunded to Atty on 07/17/07 Mileage 13.20 Misc. Surcharge 30.00 Levy 20.00 Post Pone Sale Certified Mail Postage Garnishee TOTAL 9.00 ? 54 ? ??? `??? -7 93 So Answers . ; ? 10 ° k R. Thomas Kline, Sheriff 0 By q 1 ;g d Z - AON 9001 t & j95717 `l WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 05-6072 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From APRIL DELLINGER, 1181 KINGSLEY ROAD, CAMP HILL, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of MEMBERS FIRST FCU, 3512 MARKET STREET, CAMP HILL, PA 17011 GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $8,267.83 Interest $327.54 Atty's Comm % Atty Paid $125.86 Plaintiff Paid Date: OCTOBER 25, 2006 (Seal) L.L. $.50 Due Prothy $1.00 Other Costs 614a, e4 Curtis R. Lon ro onota By; REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412434-7955 Deputy Supreme Court ID No. 47437