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Home My WebLink About06-0794IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: c)l- - 74y /7 / 1 l_tvL ?lL)rl vs. COMPLAINT IN CIVIL ACTION SIDEN NOD Defendant 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 04956868 C A Pit WLG IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No Q(o - '/ 9`% SIDEN NOU Defendant COMPLAINT AND NOTICE TO DEFEND 6-o -uL`-7k6,J 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: SIDEN NOU 320 LIBERTY CT MECHANICSBURG, PA 17050 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011002130289655 . 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 January 31, 2006 , in the amount of $8234.96 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 , SIDEN NOU INDIVIDUALLY , in the amount of $8234.96 with interest at the legal rate of 6.0001 per annum from date of judgment plus attorneys' fees of $1000.00 , and costs. James Warmbrodt,42524 WELTM WEINBERG & REIS CO., L.P.A. 436 e enth Avenue, Suite 2718 Pit sb rgh, PA 15219 (41 ) 434-7955 FAX:/412-338-7130 049X6868 C A Pit WLG This law firm is a debt collector att/mpting to collect this debt for our client and any information obtained will be used for that purpose. t e January 16, 2006 17 SDSN6A01 0001408 SIDEN NOU 320 LIBERTY CT MECHANICSBURG PA 17050-1830 Address or telephone change? Please print change in the space above, or go to Discovercam com. PO BOX 15251 Illrrrll"""III...I"I'll WILMINGTON DE 19886-5251 111 III IIl1III III III III HIIIII III III III Iif IIIII III III IIII III III 000006011002130289655082349600000000106800 Discover Platinum Card Account Summary Closing Date: December 17, 2005 page 1 of 1 account number payment due date minimum payment due credit limit credit available cash credit limit cash credit available 6011 0021 3028 9655 January 16, 2006 $1,068.00 $7,800.00 $0.00 $3,900.00 $0.00 To order Cash Access Checks, select your P.I.N., or to find cash locations call 1-800-DISCOVER (1-800-347-2683) or visit Discovercard.com. previous balance $8,234.96 payments and credits - 0.00 purchases + 0.00 cash advances + 0.00 balance transfers + 0.00 FINANCE CHARGES + 0.00 new balance = $8,234.96 Cashback Bonus® Opening Cashback Bonus Balance New Cashback Bonus Earned $ + 0.00 0.00 Cashback Bonus Balance $ 0.00 Available to Redeem $ 0.00 Cashback Bonus® Anniversary Date: June 17 --------- ------- .EXHIBIT.-..-- - - 4 Nominal ANNUAL Transaction Average Daily ANNUAL Periodic Fee Daily Periodic PERCENTAGE PERCENTAGE FINANCE FINANCE Balances Rates RATES RATES CHARGES CHARGES current billing period: 30 days Purchases $0 0.07395% 26.99% V 26.99% $0 none Cash Advances $0 0.07395% 26.99% V 26.99% $0 $0 The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above. VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, he/she is an attorney for the Plaintiff herein; makes this Verification based upon the facts as supplied to her by the Plaintiff and/or its agents and because the Plaintiff is outside the jurisdiction of the court and the Plaintiff's Verification cannot be obtained within the time allowed for filing of this pleading, and that the facts set forth in the foregoing pleading are true and correct to the best of her knowledge, information and belief. 04956868 C A Pit WLG pj C SHERIFF'S RETURN - REGULAR CASE NO: 2006-00794 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS NOU SIDEN BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon NOU SIDEN DEFENDANT the , at 1957:00 HOURS, on the 14th day of February , 2006 at 320 LIBERTY COURT MECHANICSBURG, PA 17050 by handing to SIDEN NOU a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.80 Affidavit .00 Surcharge 10.00 .00 36.80 Sworn and Subscribed to before me this :!At day of VIA Jar) G A. D. Prot no So Answers: f/ R. Thomas Kline 02/17/2006 WELTMAN WEINBERG REIS By:?,? /?1 Deputy Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. SIDEN NOU Defendant No.: 06-794 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOLCZAN, ESQUIRE PA LD.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W W R,?04956868 Judgment Amount $ 9,234.96 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. SIDEN NOU Defendant Civil Action No.: 06-794 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, SIDEN NOU above named, in the default of an Answer, in the amount of $9,234.96 computed as follows: Amount claimed in Complaint $8,234.96 Interest from date ofjudgment at the legal interest rate of 6% per annum Attorney's fees $1,000.00 TOTAL $9,234.96 1 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, W EINBERG & REIS CO.. L.P.A. By: "? _? ?L WILLIAM T. MOLCZA , SQUIRE PA I.D.#47437 Welunan, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#04956868 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7°i Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 320 LIBERTY CT MECHANICSBURG,PA 17050 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff SIDEN NOU vs. Civil Action No.: 06-794 CIVIL TERM 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 _Npa: ( _4q4 )? ODD (xx) Assumpsit Judgment in the amount of $9,234.96 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 ofIudgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: PROI9NOTA DEPU Y) SIDEN NOU 320 LIBERTY CT MECHANICSBURG,PA 17050 Plaintiffs address is: c/o Wettman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7"' Avenue Pittsburgh, PA 15219 1-888-434-0085 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. SIDEN NOU Defendant Case no:: 06-794 CIV [L TERM 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, Af iant 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, SIDEN NOU 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, SIDEN NOU is not in the military service. Further Affiant sayeth naught. /- ` AFPIANT SW7 T, ND UBSCR ED in my presence th s )C- NOTARY PUB 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 I of l MAR-24-2006 07:04:15 C Last Name First/Middle Begin Date Active Duty Status Service/Agency NOU SIDEN 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. 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: http://,Aww,defenselink.mil/faq/pis/PC09SLDR.hiinl. WARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID. QFMGRIGXHP https://www.dmde.osd.mil/scra/owa/scra.prc_Select 3/24/2006 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff SIDEN NOU Defendant(s) IMPORTANT NOTICE TO: SIDEN NOU 320 LIBERTY CT MECHANICSBURG,PA 17050 Date of Notice: ?7 J WWR#: 04956868 Case # J6 / -T?fy 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 BY : /?/r" 6' JAMES W' MBRO T, ESQUIRE PA I.Dt #42524 WELT , WEINBERG & REIS CO., L.P.A. 2718iK PPERS BLDG, 436 7TH AVE. PITT,S RGH, PA 15219 ? ?' ? ? C ,., ' {, , (? ? 9,, ? ? ? ---. _ . ? h r! V4 14 4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. SIDEN NOU Defendant SUSQUEHANNA CU, Garnishee, J; Je? No IA e+P.+??unT , J 39,0 LJbe fY e' Fleck"i c.st,.-j, P4. 1705"0 No. 06-794 CIVIL TERM 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#04956868 1213 SWe, 9,11 Ro4l, C4 kmr d it t , Ph. /7011 ,r 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. SIDEN NOU Defendant SUSQUEHANNA CU, Garnishee TO THE PROTHONOTARY: Civil Action No. 06-794 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION Kindly issue a Writ of Execution in the above matter... I . directed to the Sheriff of Cumberland County: 2. against Siden Nou, Defendant 3. against Susquehanna CU, Garnishee 4. Judgment Amount $ 9,234.94 Interest $ 227.71 Costs $ SUBTOTAL: $ 9,462.65 Costs (to be added by Prothonotary): $ WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. Molczan, Es e PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04956868 c. L o mow. 71- l?l 1 ? w 1 r WRIT OF EXECUTION and/or ATTACHMENT s I % COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-794 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From SIDEN NOU, 320 LIBERTY CT., MECHANICSBURG, PA 17050 (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 SUSQUEHANNA CU, 1213 SLATE HILL ROAD, CAMP HILL, PA 17011 - GARNISHEE 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 $9,234.94 Interest $227.71 Atty's Comm % Atty Paid $119.30 Plaintiff Paid Date: SEPTEMER 21, 2006 (Seal) L.L. $.50 Due Prothy $1.00 Other Costs Curtis R. Long, Pro ary By: Deputy 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 Supreme Court ID No. 47437 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. SIDEN NOU Defendant No.: 06-794 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END AS TO SUSQUEHANNA C. U. ONLY FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James W. Warmbrodt PA I. D #42524 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#04956868 IN THE COURT OF COM DISCOVER BANK Plaintiff vs. SIDEN NOU Defendant PRAECIPE TO SETTLE TO THE PROTHONOTARY OF SIR: N PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Civil Action No.: 06-794 CIVIL TERM 3CONTINUE AND END MBERLAND COUNTY: EHAN Settle, Discontinue and End the above-captioned matter as to SUSQUEHANNA C.U. only, upon the records of the Court without pre'udice to refile and mark the costs paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: Attorney for PI 'ntiff 2718 Kopper uilding 436 Sevent A enue Pittsburgh P 15219 (412) 43 79 5 SWORN TO AND SUBSCRIBED before me this ? day of CSC?- Y- , 2006 NOTARY PUIWC ;OMMONWEALTH OF PENNSYLVANIA N0ta68i Sea sea' Public ---Wendy L. Gault, Notary County coy of Pittsburgh, A IV My commission t„ 7t?ireS July 15, 201 ___ U Member, Pennsylvania AssaciaCr of I\iotaries n ----a -77 7"_ -77 VN ?" ) SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-00794 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND DISCOVER BANK VS NOU SIDEN And now SHARON LANTZ Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0011:45 Hours, on the 4th day of October , 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT , NOU SIDEN in the hands, possession, or control of the within named Garnishee SUSQUEHANNA CU 1213 SLATE HILL ROAD CAMP HILL, PA 17011 Cumberland County, Pennsylvania, by handing to JAYME EMERSON (TELLER) personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to Her Sheriff's Costs: Docketing Service Affidavit Surcharge Sworn and Subscribed to before me this true and made So answers- .00 .00 t° .00 R. Thomas Kline .00 Sheriff of Cumberland County .00 0 0 ? ib?<b?a 4 1 /05/2006 day of By %kkj j Deputy Sheriff A.D IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. SIDEN NOU Defendant Civil Action No.: 06-794 CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. Sworn to and subscribed before me this IL)4-h day of November, 06 NOTARY PU ',unaM _N 4TH C?K EN SYLVANIA Notarial Seal Heim J. Kelly, Notary Pd* Y -Of Pittst urgh, AlleghenyCoiu!N., ommiss*n Expaes Nov.. _ MNr ,, • ennsvlv2nia Associati,_ ' _?as WELTMAN, WEINBERG & REIS CO., L.P.A. By: r s James armbrodt PA I .D D 25 4 WELT AN, EINBERG & REIS CO., L.P.A. 2718 Ikopp rs Building 436 Oeve h Avenue Pittsburg , PA 15219 (4121) 4 -7955 WWR #04956868 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. SIDEN NOU Defendant No.: 06-794 CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT 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 WWR#04956868 ^-7 _ ,t ._ __ _{ -1 ,, ? .. ._ ' s ,,-- ... ??.`, - ,? ? '7 ,? _ i. !-.- - .1% IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA MANOR HEALTHCARE CORP. d/ b/ a : MANORCARE HEALTH SERVICES - CARLISLE, Plaintiff, V. RICHARD DICK, in his capacity as Executor of the Estate of Paul E. Dick. Defendant. No. 06-824 Civil Term CIVIL ACTION - LAW MORTGAGE FORECLOSURE PRAECIPE TO SETTLE, DISCONTINUE, AND END TO THE PROTHONOTARY: Kindly mark the above-captioned matter as Settled, Discontinued, and Ended. Respectifully Sumitted, BOGAR LLC Dated: ,t ` 120 A'G By: Wdley 1e5chutjer Attorney ID No.: 75954 305 N. Front Street, Suite 401 Harrisburg, PA 17101 (717) 909-5921 Attorneys for Plaintiff CERTIFICATE OF SERVICE I hereby certify that a true and correct copy of the foregoing Praecipe to Settle, Discontinue, and End was served via first-class, United States mail, postage prepaid, upon the following: Richard Dick, Executor 671 Old Mill Road Newville, PA 17241 Dated: D By: isty o g, Parale ?? ,--; ca ' % ? ..?1 .r t '. r- - -,r ?'. 'L", 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 ' s Costs 94.44 Sheriff ?ocketing 18.00 55.56 oundage 1.86 Advertising Law Library I? ? .50 . Prothonotary 1.00 Refunded to Atty on 09/12/07 Mileage 14.08 Misc. Surcharge 30.00 Levy 20.00 Post Pone Sale Certified Mail Postage Garnishee TOTAL 9.00 94.44 ? 11-14101 o Answers, .?? R. Thomas Kline, Sheriff By a 80 :b V 9Z d3S 9001 bd ,kjhf'iQ;i (i? v' i i kill 33183HS 3141 JO 3jujo i) p a r WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-794 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From SIDEN NOU, 320 LIBERTY CT., MECHANICSBURG, PA 17050 (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 SUSQUEHANNA CU, 1213 SLATE HILL ROAD, CAMP HILL, PA 17011 - GARNISHEE 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 $9,234.94 Interest $227.71 Atty's Comm % Atty Paid $119.30 Plaintiff Paid Date: SEPTEMER 21, 2006 (Seal) REQUESTING PARTY: L.L. $.50 Due Prothy $1.00 Other Costs ( ?94 Curtis R /tong, Pro By: Deputy Name WILLIAM T. MOLCZAN, ESQUII E Address: WELTMAN, WER411 RAG & RIM CO., L.P.A. 2718 KOPPERS BUILDJ NG 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 47437