HomeMy WebLinkAbout02-1420JNWEALTH OF PENNSYLVANIA
COURT OF COMMON PLEAS
JUDICIAL DISTRICT
NOTICE OF APPEAL
FROM
DISTRICT JUSTICE JUDGMENT
co.,,o.,.,As.o.
NOTICE OF APPEAL
Notice is given that the appellant has filed in the above Court of Common Pleas an appeal from the judgment rendered by the District Justice
on the date and in the case mentioned below.
NAME OF APPELLANT MAG. DIST. NO. OR NAME OF D.J.
DISCOVER BANK, ISSUER_ OF DISfI)9~ 9-3-1
ADDRESS OF APPELLANT CITY STATE ZIP CODE
c/o Edward Stock, Esq~, 18th Fl., 1608 Walnut St., Phila., PA 19103
3/6/02 is.u vs.
CVLT 2020 02-23 EUNARD 3~
This block will be signed ONLY when this notation is reqmred under Pa. I~-~e~.P.J.P: '
R.C.P.J.P.
No.
1008B.
No. 1001(6) in action before District Justice, he
This Notice of Appeal, when received by the District Justice, will operate as
a SUPERSEDEAS to the judgment for possession in this case. MUST FILE A COMPLAINT within twenty (20)
clays a~tor filing his NOTICE of APPEAL.
Signature of Prothonotary or Deputy
PRAECIPE TO ENTER RULE TO FILE COMPLAINT AND RULE TO FILE
(This section of form to be used ONLY when appellent was DEFENDANT (see Pa. R.C.P.J. Po No. 1001(7) in action before District Justice.
IF NOT USED, detach from copy of notice of appeal to be served upon appellee).
PRAECIPE: To Prothonotary
Enter rule upon
(Common Pleas No.
· appellee(s), to file a complaint in this appeal
Name of appellee(s)
) within twenty (20) days after service of rule or suffer entry of judgment of non pros.
RULE: To , appellee(s)
Name of appellee(s)
Signature of appellant or his attorney or agent
Date:
· 20 .
(1) You are notified that a rule is hereby entered .~?n you to file a complaint in this appeal within twenty (20) days after the date of
service of this rule upon you by personal sergice or!by certifi~i:l.'or re~istered mail.
~ ::-'~ .
(2) If you do not file a complaint within th.ts tir0e; a:,JUDGME'NT~(~F NON PROS WILL BE ENTERED AGAINST YOU.
(3) The date of service of this rule if service ~as ~ ;mail.is the}~late 0..f mailing.
Signature of Prothonotary or Deputy
AOPC 312~90 COURT FILE TO BE FILED WITH PROTHONOTARY
PROOF OF SERVICE OF NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
(This proof of service-MUST BE FILED WITHIN TEN (10) DA YS AFTER filing the notice of appeaL-Check applicable boxes)
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF
AFFIDAVIT:
hereby swear or affirm that I served
; SS
[] a copy of the Notice of Appeal, Common Pleas No. , upon the District Justice deSignated therein on
(date of servicel ' , 20 [] by personal service [] by (certified) (registered) mail,.ser~er's
receipt attached hereto and upon the appellee, (name)
on , 20__ [] by personal service [] by (certified) (registered) mail, sender's receipt attached hereto.
[] and further that I served the Rule to File a Complaint accompanying the above Notice of Appeal upon the appellee(s) to
whom the Rule Was addressed on ; 20 , [] by personal service [] by (certified) (registered)
mail, sender's receipt attached hereto.
SWORN (AFFIRMED) AND SUBSCRIBED BEFORE ME
THIS DAY OF , 20
Signature of affiant
Signature of official before whom affadavit was made
Title' of official
My commission expires on
COMMONWEALTH OF PENK' '_VANIA
COUNTY OF: CUMBERT.AN~
Mag. Dist. No.:
09-3-01
DJ Name: Hon.
HAROLD E. BENDER
AOd~ess: 81 W~T.NUT BOTTOM ROAD
P.O. BOX 361
SHIPPENSBURG, PA
Telephone: (717) 532 '7676 17257 ' 0361
DISCOVER FINANCIAL SRV, INC
1608 WALNUT ST
C/O EDWARD STOCK
PHILADELPHIA, PA 19103'
NOTICE
PLAINTIFF: CIVIL CASE
NAME and ADDRESS
~ISCOVER BANK, ISSUER OF DISCOVER
1608 WALNUT ST
C/O EDWARD STOCK
~HILADELPHIA, PA 19103
VS.
DEFENDANT: NAME and ADDRESS
~UNLAP, DORY A
98 LOCUST ST
SHIPPENSBURG, PA 17257-1714
JUDGMENT/TRANSCRIPT
Docket No.: CV-0000023-02
Date Filed: 2/04/02
THIS
IS TO NOTIFY YOU THAT:
Judgment:
Judgment was entered for: (Name)
. Judgment was entered against: (Name)
in the amount of $ 00 on:
Defendants are jointly and severally liable.
Damages will be assessed on:
(Date of Judgment) ~/0~/02
(Date & Time)
This case dismissed without prejudice.
Amount of Judgment Subject to
AttachmentJAct 5 of 1996 $
Levy is Stayed for days or ~ generally stayed.
Objection to levy has been filed and hearing will be held:
Amount of Judgment $ o 00
Judgment Costs $ o 00
Interest on Judgment $ ° 00
Attorney Fees $ o 00
Total $ .00
Post Judgment Credits $,
Post Judgment Costs $.
Certified Judgment Total
Date:
Time:
Place:
ANY PARTY HAS THE RIGHT TO APPEAL WITHIN 30 DAYS AFTER THE ENTRY OF JUDGMENT BY FILING A NOTICE
OF APPEAL WITH THE PROTHONOTARY/CLERK OF THE COURT OF COMMON PLEAS, CIVIL DIVISION. YOU
MUST INCLUDE A COPY OF THIS NOTICE OF JUDGMENT/TRANSCRIPT FORM WITH YOUR NOTICE OF APPEAL.
,L,~- (m'-O ~k, Date ,/~/~,,c,¢J~/~ ~ , District Justice
I certify that this is a true and correct copy of the record of the proceedings containing thI judgment.
., Date District Justice
My commission expires first Monday of January,
AOPC 315-99
2006 SEAL
_ P1~,O.¢O.~.~-:O¢:-SERVICE .OF *~NOTICE OF APPEAL AND RULE TO FILE COMPLAINT
:~'~f ~vie~BE FILED'W/THIN TEN (10) DAYS AFTER filing the notice of appeal. Check applicable eoxes,
CoMMONW~ALTH OF PENNSYLVANIA
COUNTY' O~~ ; ss
AFFIDAVIT: I hereby swear or affirm treat served
[] a copy o~,t~ (',~j~ic~,~f,,.Ap~peelf~Commorr Pleas Nq.02-1~4~0 , upon the District Justice designaterJ therein on
~:~t.' ~-.l~[~'~l~lltYt~ J~l~5~t, 2,5, , 20 02 , ' - [] by personal service [] ' by (certified) (registered) mai[, sender's
receipt attached hereto and upon the appellee, tname) , ]]0~[ J~. D~J~
on [~JEC,~ ~5 , 20 02 [] by personal service ~ by certified) (registered) mail, sender's receipt attached hereto.
;~-.,~ ~ and, further that I served'the Rule to File a Complaint accompanying the above Notice of Appeal upon the appellee(s) to
whom the Rule was addressed on 20 (registered)
mN sender's receipt, attached hereto.
;.. RN"{~'~FfRM~} :~.i SUBSCRIBED BEFORE ME
- ;20 02.
i~ato~e ~' ~a~ '~m ,~ ~ffadavit was made
My commiss~n e~imS on , 20
March 25, 2002
Hon. Harold E. Bender
District Court 9-3-1
81 Walnut Bottom Road,
P.O. Box 361
Shippensburg, PA 17257
Ms. Dory A. Dunlap
98 Locust Street
Shippensburg, PA 17257
Re: Discover Bank,
Dory A. Dunlap
District Court
No. CV-23-02
issuer of Discover vs.
9-3 -1
Court of Common Pleas
Cumberland County
No. 02-1420
Dear Sir:
On behalf of the plaintiff, Discover Bank, issuer of Discover,
enclosed please find a true and correct copy of a Notice of
Appeal, the original of which was filed with the Court of Common
Pleas on March 25, 2002 in regard to the above matter.
Please be guided accordingly.
Very truly yours,
EDWARD STOCK
ES:kd
Enclosure
CERTIFIED MAIL, RRR
THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT
TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR
THAT PURPOSE.
March 25, 2002
Hon. Harold E. Bender
District Court 9-3-1
81 Walnut Bottom Road,
P.O. Box 361
Shippensburg, PA 17257
Ms. Dory A. Dunlap
98 Locust Street
Shippensburg, PA 17257
Re: Discover Bank, issuer of Discover vs.
Dory A. Dunlap
District Court 9-3-1
No. CV-23-02
Court of Common Pleas
Cumberland County
No. 02-1420
Dear Ms. Dunlap:
On behalf of the plaintiff, Discover Bank, issuer of Discover,
enclosed please find a true and correct copy of a Notice of
Appeal, the original of which was filed with the Court of Common
Pleas on March 25, 2002 in regard to the above matter.
Please be guided accordingly.
Very truly yours,
EDWARD STOCK
ES:kd
Enclosure
CERTIFIED MAIL, RRR
THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS A.N ATTEMPT
TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR
THAT PURPOSE.
EDWARD STOCK, ESQUIRE
I.D.#13657
18th Floor
1608 Walnut Street
Philadelphia., Pa 19103
(215)893-9322
Attorney for:
Plaintiff
DISCOVER BANK, ISSUER OF DISCDVER CARD BY ITS
AGt~qT DIS(/ArE~ FINANCIAL SERVICES, INC. COURT OF COMMON PLEAS
P.O. Box 6011 OF (/3MBERLAND COUNTY
Dover, DE 19903-6011 CIVIL ACTION - LAW
Plaintiff
vs.
DORY A. IX3NLAP
98 Locust Street
Shippensburg, PA 17257
NO. 02-1420
Defendant
"NOTICE
"You have been sued in court. If you w~sh to defend
against the claims set forth in the following pages, you must
~ake action within twenty (20) days after this complaint and
notice are served, by entering a written appearance personally
or by attorney and filing in writing with the cour~ your de-
fenses or objections to the claims set forth against you. You are
warned [hat i/you fail to do so the case may proceed w-ithout
you and a judgment ma), be entered aga rmt oub the court.
wl~out further notice for any money cla~med m the complaint
or for any other claim or relief requested by the pla~ntiff You
may lose mO.ey ut e~gnerty or other r ghta important to you.
"YOU SHOULD TAr
'. ' ' ~r nav~ A LAI%-fER OR CA-N-
NOT .~2vFOPD ONE. GO TO OR
SET FQ~T BEL')w TO
GET LEGA. HELF - FIND OUT WHERE YOU CAN
"AVISO
sfas demandas expuastas en las paginas
siguientes, usted tiene veinte (20) di~,s de plato al partir de
la fecha de la demanda y la notification. Haeo falta asentar
una compaxencia eserita o en persona o eon un abegado y
entregar a la corte en forma eserita sus degeasas o sus ob,ieci-
ones a las demandas en contra de su persona. Sea avisado
que si usted no se defiende, la torte tomarti medidas y puede
continuar la demanda en contra suya sin previo aviso c notifi.
cacioh, Adem~/s, la torte puede decidir a favor del deman-
dante y requiere que usted cumpla eon tedas la~ p.~ovisiones
de asia demanda. Usted puede perder dlnero o sas prvpieda-
des u otros derechas impertantes para usted.
"LLEVE ESTA DEMANDA A UN ABOGADO LNMEDIATA.
MENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DLN-
ERO SUFICIENTE DE PAGAR TAL SERVICI0, VAYA EN
PERSONA 0 LL,LME POR TELEFONO A LA 0FiCINA
CUYA DIRECCION SE ENCUENTRA ESCRITA AB;JO
PARA AVERIGUAR DONDE SE PUEDE CONSEGLrII~
ASISTENCIA LEGAL.
Court A~ministrator~
One Courthouse Square
4th Floor
Carlisle, PA 17013
(717)240-6200
EDWARD STOCK, ESQUIRE
I.D.#13657
18th Floor
1608 Walnut Street
Philadelphia, Pa. 19103
(215) 893-9322
Attorney for Plaintiff
DISCOVER BANK, ISSUER OF
DISCOVER CARD, BY ITS AGENT
DISCOVER FINANCIAL SERVICES,
INC.
P.O. Box 6011
Dover, DE 19903-6011
Plaintiff
vs.
DORY A. DUNLAP
98 Locust Street
Shippensburg, PA 17257
Defendant(s)
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL ACTION-LAW
NO. 02-1420
CIVIL ACTION
COMPLAINT IN ASSUMPSIT
1. Plaintiff, Discover Bank, issuer of Discover
Card, by its agent Discover Financial Services, Inc.,
is a duly organized banking institution under the laws
of the State of Delaware and has a principal place of
business at the address contained in the above caption.
2. Defendant(s), Dory A. Dunlap, is an adult
individual and resides at the address contained in the
above caption.
3. After application by the Defendant(s) to the
Plaintiff for a credit card account, which application
was approved by the Plaintiff, the Plaintiff issued a
credit card to the Defendant(s) so that the
Defendant(s) could make purchases from merchants, on
credit, who had established a business relationship
with the Plaintiff in regard to the same.
4. Plaintiff attaches hereto a copy of the
standard Cardmember Agreement to this Complaint as
Exhibit "A" which contains the terms and conditions of
the undertaking between the Plaintiff and the
Defendant(s).
5. Thereafter, the Defendant(s) utilized the said
credit card on various and sundry occasions.
6. Plaintiff attaches hereto as Exhibit "B" to
this Complaint, a true and correct copy of the last
monthly statement in regard to the activities in
connection with the Defendant's account and also
attaches hereto as Exhibit "C" to this Complaint, an
Affidavit from the Plaintiff attesting to the present
balance due the Plaintiff from the Defendant(s) in
regard to the said account.
7. Notwithstanding repeated requests and demands
of the Plaintiff upon the Defendant(s) to satisfy the
outstanding indebtedness in the sum of $3,085.28, the
Defendant(s) has and still refuses to pay the same.
8. As a result thereof, Plaintiff has been forced
to incur reasonable attorney collection fees in the sum
of $462.79 in an attempt to legally enforce collection
of the debt due it from the Defendant(s), which
reasonable attorney fees are the responsibility of the
Defendant(s) to pay in accordance with the Cardmember
Agreement.
9. THIS COMMUNICATION IS FROM A DEBT COLLECTOR.
THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
W~REFORE, Plaintiff, Discover Bank, issuer of
Discover Card, by its agent Discover Financial
Services, Inc., demands Judgment against the
Defendant(s), Dory A. Dunlap, in the sum of $3,548.07
with interest and costs.
DATE:~
EDWARD ~OC~, EsQ~
VERIFICATION
EDWARD STOCK, ESQUIRE, Attorney for Plaintiff herein,
verifies that the statements made in this Pleading are
true and correct and that he is authorized to make them
on behalf of the Plaintiff. He understands that the
statements herein are made subject to the penalties of
18 Pa. C.S.A. Sec. 4904, relating to unsworn
falsification to authorities. '~/
CARDMEMBER AGREEMENT
read ~i.~ Agreomem r.,lr~tull), be ore oeio our Disc
AC;~CE ~F AGR~ ~e usa °f veurAcc:unt ~r ~ ~rd b
LI,~liLITY FOR UNAUTHORIZED USE. If i Carl Jo lost or s;oien, or it you
E ;~88m,60~. You may be m[aoie for me unaumom< u.e of = Cato oryour
C~E~ff LIMIT. We will aUvise you o( youc c;~c~ :imiL We ma [nc':~a r
~low your unoaio balance. ~nc~uding =.*
PROMISETO PA * . ·
/or~n cu~enc/to U.S. Doi~ at a rote exi~ng an
MO~LY 31~iNG ~A~T. We w)ll sen~ 'mu
~O~dL7 ~AY~E~ ~ON$." *' ' New
to 'is n Oe~,,~ it ,-g ~ox ~J ,, Dover. ~:
TR~NSACTiON FEE FINANCE C:-IARGcS. Va ,v,I cna ge you a
Fee F~n~c~ :h~ ~a ,~f 2 5~ '" - '
is ~ mimm~m Trsnszc::on Fee ~ENANCE CHARGE at S2.,]O ~nd ~o m~imum
Tm~c.on ..... IA,IC~ C,,AR~:. ~ne imoosi~on at Trisection Fee
ad.cas, inFiUcing me m of Oisco, er Card c~, regamless of ~e pup
oaic FINANCE CH~G~ ot [~ss ~ ~.Sd ~ut~ a~er~ ~e ~maos~.
R~RNEg CHE~X .... ,Ye ~ I cna~ you a Re~med Ch~ ~ o~
~ ~,We ~}[ c~a~e you a ~ ~ of ~O.O0 2you ~[ o
mqu r~ payment ~in 20 c~ a~ar ~a P~me~ Due O~ ~n ~ mon~.
R~CH ~. ,Ve m,y c,~r~e you a ~e~mn ~ ~ ~.00 for e~h
~ ~ ~s or Y you ~xc~ your credit :im~ due ~o ~e ~os~ng of
O~=~gLT~OLLE~QN COS~ You ~ra in demu~ ~you bmme ~nsoiv~
y~u ? ~ ~ruo~,, pe~sn cr have one fiI~ ;~n=' au. or ~ you
~m~n: ~c~ .;we is ~cc:r~ng ;o :~e :~rms of ~his Agr~emenL [ your
to companies se{ling p~uc~ or se~ic~ ~A= ~a7 be a n~rest Ia yom ~ur
~rdmembem w~om na~ ta you. We ~4y
womng; we ~ not ~e ~te to ~o~
:o yau ~ ~ ~ ~e ~en~ h~ppen.
C~GE OF ~MS, ~ reexchange a~ tern or ~a~.~ ~i~ A~ement,
inctu~iaq a~ fl~nce :ha~e n~, fee or m~od ~ c~mp~ng any balance
pay ~ ~e ~alafln ~at you owe ~
~eemed 3~n~ ~ me new te~s ~ of ;c~ effete ~ate, oven ff yea
p~o~ n~ed ~ ~ yeu did ~ ;q~e to ~e ~a~e. "
~GE OF AOORE~S. ~f '/~u ~'~
your ~ ad~'~in 15 ~"~,
~IG~ OF AC:~U~. We may s~L ~n ar~er ~r~un: or
~ ~cn m~o~ qo~ :o you. ~p ~ n~l, ~:~n ar~er
a~scg~o
6011 0022
DUNLAP, DORY A
5058 3754
CREDIT LIMIT: 2100
CREDIT AVAIL: 0
MULTIPLE STATEMENTS
OTHER/MISCELLANEOUS
CARDMEMBER STATEMENT
14:03:24
PAYMENT DUE DATE:
MIN PAYMENT DUE:
AMOUNT PAST DUE:
CLOSING DATE: 12/16/00
VIEW DATE: 12 / 00
01/13/01 PREVIOUS BALANCE:
453.00 PAYMENTS/CREDITS: -
388.00 PURCHASES/MISC: +
CASH ADVANCES: +
BALANCE TRANSFERS +
FINANCE CHARGES: +
NEW BALANCE:
12/16 LATE FEE
12/16 OVERLIMIT FEE
Ol/O9/O
2973.07
0.00-
58.00
0.00
0.00
54.21
3085.28
29.00
29.00
F9-PREV F10-NEXT Fll-VIEW DETAIL
MSG: LAST PAGE OF THE STATEMENT
F5-CBB
F6-FC
F13-MSG F14-ADJ F15-REPRINT
EXHIBIT "B"
ATTORNEY: STOCK
6011002250583754
BALANCE:
CARDMEMBER(S):
$3085.28
DORY A DUNLAP
STATE OF OHIO
COUNTY OF FRA/NKIN
V. Williams, personally appeared before me, this day and after being duly
sworn, according to law, upon her oath and says:
THIS person is a Legal Placement Account Manager for
DISCOVER FINANCIAL SERVICES INC.,the servicing agent of DISCOVER BANK,
an FDIC insured Delaware State Bank.
THAT, in their capacity as Legal Placement Account Manager, Affiant has control
over and access to records regarding the account of this debtor; further that
the Affiant has personally inspected said account and statements regarding the
balance due on said account. These Records are kept in the normal course of
business.
THAT the undersigned Affiant being duly sworn deposes and says that the policies
and procedures of DISCOVER BANK and it's servicing agent, DISCOVER
FINANCIAL SERVICES, INC. are in accordance with applicable federal and state
consumer and credit laws.
THAT the annexed statement of account, in favor of DISCOVER BANK, is
a true and correct statement and there is now due and owing to DISCOVER BANK,
the sum over and above all legal set-offs. 'Attached' hereto as
exhibit A is a copy of the terms of the account which we forwarded with the
charge card to the Cardmember(s).
THAT to the best of Affiant's knowledge and belief the defendant is employed in
civilan life and by reason thereof is not engaged in the military service of the
United States and is a resident of the State and of the Country in which this
action has been filed.
THAT this affidavit is made on the basis of Affiant's personal knowledge and in
support of Plaintiff's suit on account against said Debtor.
Beth A. Oakley
NOTARY PUBLIC, STATE OF OHIO
MY COMMISSION EXPIRES 02-15-05
Affiant
Sworn and Subscribed before me
this 8TH day of J/LN-UARY, 2001
Notmy Public
In and for the State of Ohio
· .......
EXHIBIT "C"
1.4.02/revised 3.25.02
Inventory of Diane L. Greene
DIANE L. GREENE,
Plaintiff
ROBERT F. GREENE,
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
NO. %5 O C vlu
CIVIL ACTION - LAW
IN DIVORCE
INVENTORY OF DIANE L. GREENE
Plaintiff files the following inventory of all property owned or
possessed by either party at the time this action was commenced and all
property transferred within the preceding three years.
Plaintiff verifies that the statements made in this inventory are true
and correct. Plaintiff understands that false statements herein are made
subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn
falsification to authorities.
Dated: 3-3~~0~
~le Road
Camp~ill, PA 17011
Phone: (717) 737-0100
Fax: (717) 975-0697
Supreme CourteD #32112
Dated: ~/ /0 ~--
Page 1
ASSETS AND LIABILITIES OF PARTIES
Plaintiff marks on the list below those items applicable to the case at bar and
itemizes the assets and debts on the following pages:
(x)
(x)
( )
( )
(x)
(x)
)
)
)
)
(x)
(x)
( )
( )
( )
( )
( )
(x)
( )
( )
(x)
( )
1. Real property and Real Estate Mortgages
2. Motor Vehicles and Vehicle Liens
3. Stocks, bonds, securities and options
4. Certificates of Deposit
5. Checking accounts, cash
6. Savings accounts, money market and savings certificates
7. Contents of safe deposit boxes
8. Trusts
9. Life Insurance policies (indicate face value, cash surrender value and
current beneficiaries)
10. Annuities
11. Gifts
12. Inheritances
13. Patents, copyrights, inventions, royalties
14. Personal property outside the home
15. Business (list all owners, including percentage of ownership, and
officer/director positions held by a party with company)
16. Employment termination benefits - severance pay, worker's compensation
claim/award
17. Profit sharing plans
18. Pension Plans (indicate employee contribution and date plan vests)
19. Retirement plans, Individual Retirement Accounts
20. Disability payments
21. Litigation claims (matured and unmatured)
22. Military/V.A. benefits
23. Education benefits
24. Debts due, including loans, mortgages held
25. Household furnishings and personalty (include as a total category and
attach itemized list if distribution is in dispute)
26. Other assets
27. Loans
28. Credit Cards
29. Other Debts
Page 2
I. MARITAL PROPERTY AND MARITAL LIABILITIES
Plaintiff lists all marital property in which either or both spouses
have a legal or equitable interest, individually or with any other person as
of the date of separation and, all marital liabilities owed by either or
both spouses, individually or with any other person as of the date of
separation:
NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED
PROPERTY OR VALUE ASSET OR DISTRIBUTION DISTRIBUTION
LIABILITY LIABILITY TO HUSBAND TO WIFE
CUMBERLAND, PA
GmO MORTGACE ~22,000.00~
' MORTGAGE
NET EQUITY 56,000.00 56,000.00 28,000.00 28,000.00
A ~SEANO S ~990 3.25.02. ~,780.00
CHEVY ASTRO VAN
vE.~o~,E ~,oAN ~/A 0.00
NET VALUE 3.25.02 1,780.00 1,780.00 1,780.00
Page 3
NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED
PROPERTY OR VALUE ASSET OR DISTRIBUTION DISTRIBUTION
LIABILITY LIABILITY TO HUSBAND TO WIFE
EL~T~ LOAN o. oo
NET VALUE 0.00 0.00 0.00
C HUSBAAFD ' S 1989 1,480.00
C~EVY BLAZER
HUsbAND'S
D ~usB~,s 6,16o.oo
MOTORCYCLE
NET VALUE 6, 160.00 6, 160.00 6,160.00
E R/3S BAIRD ' S TBD
UTILITY TRAILER
HUSBAND ' S None
TRAILER LOAN
NET VALUE TBD TBD TBD
Page 4
NO DESCRIPTION OF DATE OF VAL~E OF NET VALU~ PROPOSED PROPOSED
PROPERTY OR VALUE ASSET OR DISTRIBUTION DISTRIBUTION
LIABILITY LIABILITY TO HUSBAND TO WIFE
A PSECU joint est. 100.00 100.00 100.00
checking
account #
B Wife's Waypoint 10.5.01 615.80 615.80 615.80
Bank checking
account
#0100312230
A Wife's Waypoint 10.6.01 1,234.43 1,234.43 1,234.43
Bank savings
account #
I
A Wife's SERS To be TO be To be To be
Retirement Plan divided at divided at divided at divided at
retirement retirement retirement retirement
B Husband's PSECU Est. 5,000.00 5,000.00 5,000.00
IRA
A Husband's Est. 16,915.00 16,915.00 16,915.00
Household Goods
Page 5
NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED
PROPERTY OR VALUE ASSET OR DISTRIBUTION DISTRIBUTION
LIABILITY LIABILITY TO HUSBAND TO WIFE
B Wife's Est. 1,450.00 1,450.00 1,450.00
I Household Goods
Home Depot
joint credit
card
Est. TBD TBD TBD TBD
Bank One joint Est. TBD I
credit card
TBD
TBD
TBD
Wife's Sears Est. TBD
credit card
TBD TBD TBD
Page 6
NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED
PROPERTY OR VALUE ASSET OR DISTRIBUTION DISTRIBUTION
LIABILITY LIABILITY TO HUSBAND TO WIFE
D Lowe's j oint Est. TED TED TED TED
credit card
R Walmart joint Est.
credit card
F Boscov' s joint Est. TBD TBD TBD TBD
credit card
G Discover joint Est. TBD TBD TBD TBD
credit card
Page 7
NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED
PROPERTY OR VALUE ASSET OR DISTRIBUTION DISTRIBUTION
LIABILITY LIABILITY TO HUSBAND TO WIFE
R Bank of America Est. TED TED TED TED
joint credit
card
I 1sT Union Est. TBD TBD TBD TBD
National Bank
joint credit
card
J PSECU joint Est. TBD TBD TBD TBD
Visa account
Page 8
NO DESCRIPTION OF DATE OF VALUE OF NET VALUE PROPOSED PROPOSED
PROPERTY OR VALUE ASSET OR DISTRIBUTION DISTRIBUTION
LIABILITY LIABILITY TO HUSBAND TO WIFE
K PSECU joint Est. TED TED TED TBD
credit card
account
onm~nts. ~e ha~ance ~ed On ~h~s loan as o£da~e o~se~&tion was
$1,596.00,
Wi£e has £ilea bar~ru~tcy and ~s ,paYing $214.00 per month on &
Chapter 13 PimP; As Pe~ l~t~£r~mAtt~rnay Each, wi~e,s ~14.00
ire s payment o£ th~s d~t ~il~, there£O~e, he 21% 0£ the above
I
TOTAL OF ASSETS 90,735.23 59,435.00 31,300.23
A~D LIABILITIES
Totals from above 90,735.23 59,435.00 31,300.23
Amount Due in 50/50 Division 45,367.62 45,367.62
Adjustment Figure (14,067.39) 14,067.39
Totals from above 90,735.23 59,435.00 31,300.23
Amount Due in 45/55 Division 40,830.85 49,904.38
Adjustment Figure (18,604.15) 18,604.15
Totals from above 90,735.23 59,435.00 31,300.23
Amount Due in 40/60 Division 36,294.09 54,441.14
Adjustment Figure (23,140.91) 23,140.91
NOTES
ADJUSTMENT FIGURES ARE FOR ILLUSTRATION PURPOSES ONLY. THEY ARE NOT TO
BE DEEMED A REPRESENTATION BY WIFE THAT ANY ADJUSTMENT SHOULD BE MADE.
ADJUSTMENT FIgURES WILL CHANGE WILL ANY CHANGE IN ASSET VALUE.
Page 9
IF ADJUSTMENTS ARE REQUIRED, THEY SHOULD BE MADE FIRST FROM THE SALE
VALUE OF THE MARITAL HOME AND SECOND FROM HUSBAND'S IRA AND THIRD FROM
THE DISTRIBUTION OF WIFE'S PENSION CONTRIBUTION ACCOUNT.
THE FOLLOWING AMOUNTS ARE THE AMOUNTS OF THE DEBTS BEING PAID BY WIFE IN
HER CHAPTER 13 BANKRUPTCY ~ $0.21 PER DOLLAR:
Bank of America
Choice Visa
$1,714.00
$359.94
$1,667.00 $350.07
Discover Card $2,711.00 $569.31
First USA $4,413.00 $926.73
Home Depot $1,422.00 $298.62
Providian $1,659.00 $348.39
PSECU $750.00 $157.50
PSECU Visa $7,201.00 $1,512.21
Sears $1,821.00 $382.41
TOTALS $23,358.00 $4,905.18
Page 10
II. LISTING OF HOUSEHOLD GOODS AND CONTENTS
VALUED IN SECTION I.
Plaintiff lists all household goods and contents in which either or both spouses have
a legal or equitable interest, individually or with any other person as of the date
of separation, the total value of which is specified in Section I. above:
MARITAL PROPERTY IN HUSBAND'S POSSESSION
1. Sofa Joint Husband $250.00
2. Recliner chair Joint Husband $25.00
3. 27" color tv Joint Husband $100.00
4. Surround sound Joint Husband $100.00
system
5. VCR Joint Husband $100.00
6. Lamp Joint Husband $25.00
7. King-size Joint Husband $200.00
waterbed
8. Papa-saw chair Joint Husband $50.00
9. Vanity Joint Husband $100.00
10. Gun cabinet Husband Husband $150.00
11. 4 rifles Husband Husband $1,500.00
12. 4 dressers Joint Husband $200.00
13. Computer Joint Husband $500.00
14. Boat motor & Joint Husband $1,500.00
trailer
Page 11
15. Tool box, large Husband Husband* $7,000.00 *Tool box is in
amount of auto wife's possession.
tools and 6 hp She is willing to
air compressor give to husband
provided that any
payment due her as
part of distribution
is paid.
16. Large chest Joint Husband $200.00
freezer
17. Small chest Joint Husband $50.00
freezer
18. Marble Joint Husband $1,500.00
collection
19. Marble game in Joint Husband $250.00
tin box
20. Wood lathe Joint Husband $150.00
21. Wood planer Joint Husband $150.00
22. Snow blower Joint Husband $300.00
23. Lawn mower Joint Husband $200.00
24. Gas grill Joint Husband $50.00
25. Park bench Joint Husband $50.00
26. Porch furniture Joint Husband $100.00
27 Microwave Joint Husband $300.00
28. Household tools, Joint Husband $1,000.00
drills, saws,
etc.
29. Dishes, glasses, Joint Husband $25.00
pots & pans
30. Refrigerator Joint Husband $100.00
Page 12
31. Fishing rods & Husband Husband $200.00
equipment
32. Computer desk Joint Husband $150.00
33. Entertainment Joint Husband $200.00
center
34. Refrigerant Husband Husband $90.00
gauge & hose
35. Wife's personal Wife Husband $0.00 These items are
property in van requested by wife
including 3 bins
of pictures,
state parking
pass, handicap
placard for car
pool and legal
documents
SUBTOTAL HUSBAND'S ~%RITAL PROPERTY $16,865.00
NON-MARITAL PROPERTY IN HUSBAND'S POSSESSION
36. Floor swing Wife Husband $50.00 This was made by
wife's father for
her. This items
should be returned
to her.
37. 20 silver Children Husband $200.00 These were given to
dollars the children by
their grandfather
for Christmas.
Husband needs to
provide them to the
children.
38. 4 State Hood Children Husband $100.00 Bought (Gift) for
quarter sets the children.
Husband needs to
provide them to the
children.
Page 13
39. China closet Husband Husband TBD Husband's pre-
marital. Bought
from Uncle Henry
40. Antique box with Wife Husband TBD Wife's non-marital
silverware came from wife's
father's family.
Wife wants this item
returned to her.
SUBTOTAL NON-MARITAL PROPERTY IN HUSBAND'S $350.00
POSSESSION
MARITAL PROPERTY IN WIFE'S POSSESSION
41. Sofa & love seat Joint Wife $350.00
42. Accessory tables Joint Wife $150.00
43. 2 lamps Joint Wife $50.00
44. Washer Joint Wife $100.00
45. Dryer Joint Wife $100.00
46. Dining room Joint Wife $350.00
table & chairs
47. Roll top desk Joint Wife $50.00
48. Victrola Joint Wife $50.00
49. Trash compactor Joint Wife $50.00
50. Set of dishes Joint Wife $50.00
51. 19" tv Joint Wife $150.00
SUBTOTAL WIFE'S MARITAL PROPERTY $1,450.00
NON-MARITAL PROPERTY IN WIFE'S POSSESSION
52. Secretary desk Wife Wife TBD Wife's pre-marital
53. Bedroom Wife Wife TBD Wife's pre-marital
Page 14
furniture
54. Cedar chest Wife Wife TBD Gift to Wife and
made by father
55. Grandfather Wife Wife TBD Gift to Wife and
clock made by father
56. Rocking chair Wife Wife TBD Gift to Wife and
made by father
57. Armoire Wife Wife $100.00 Gift to Wife from
children
SUBTOTAL WIFE'S NON-MARITAL PERSONAL $100.00
PROPERTY
Page 15
III. NON-MARITAL PROPERTY AND LIABILITIES
Plaintiff lists all property and/or debts in which a spouse had a legal or
equitable interest or owed as of the date of separation which is claimed to be
excluded from marital property or debts by virtue of it being acquired before
marriage, after separation or by way of gift or inheritance (for gifts also specify
person giving gift):
Husband $200.00 Gift to children.
2. ~aStr~etre_ _ sHeO~sd Children Husband $100.00 Gift to children.
I 3. ~China closet I Husband Husband TBD Husband's pre-marital
I 4_. ~ Sec. retary desk I ~lfe Wife TBD Wife's pre-marital
5. ~r~umre Wife Wife TBD Wife's pre-marital
~ 6. I Cedar__chest I Wife Wife TBD Gift to wife
7. cG~oa!!father. Wife Wife TBD Gift to wife
~ 8_. ~ _Rock~ng chairI Wife Wife TBD Gift to wife
I ~i IA.rm°ire. I Wife Wife $100.00 Gift to wife
11. ~i!~; ~X Wife Husband TBD Wife's from Wife'n°n-marital - cames father's
a family.
Page 16
IV. PROPERTY TRANSFERRED
Plaintiff lists all property which was transferred within 3 years of the date
of the commencement of this action or was transferred since the date of
separation:
None Known
Page 17
CERTIFICATE OF SERVICE
AND NOW, this day of , 2002, I, DIANE G.
RADCLIFF, ESQUIRE, hereby certify that I have this day served a
copy of the within INVENTORY, upon the following set forth person,
by mailing same by first class mail, postage prepaid, addressed as
follows:
ROBERT F. GREENE
312 EUTAW STREET
NEW CUMBERLAND, PA 17070
James L. McAneny, Esquire
P.O. Box 314
310 Third Street
New Cu/~berland, PA 17070
Respectfully submitted,
Phone: (717) 737-0100
Fax: (717) 975-0697
Supreme Court ID #32112
Page 18
EDWARD STOCK, ESQUIRE
I.D.#13657
18th Floor
1608 Walnut Street
Philadelphia, PA 19103
(215) 893-9322
Attorney for Plaintiff
DISCOVER BANK, ISSUER OF
DISCOVER CARD BY ITS AGENT
DISCOVER FINANCIAL SERVICES,
INC.
Plaintiff
vs.
DORY A. DUNLAP
Defendant
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL ACTION-LAW
NO. 02-1420
CERTIFICATE OF SERVICE
Edward Stock, Esquire, the attorney for the
Plaintiff certifies that on April 24, 2002 he mailed to
the Defendant, Dory A. Dunlap, a true and correct copy
of the Civil Action Complaint, the original of which
was filed with the court on April 8, 2002, by
depositing the letter with the United States Postal
Service, Certified Mail Receipt No. 7001-2510-0009-
3742-0807 which letter was addressed to the Defendant
at the address of 98 Locust Street, Shippensburg, PA
17257. Attached hereto is a copy of the letter dated
April 18, 2002 and the original Certified Mail Receipt
indicating that the letter was in fact deposited on
April 24, 2002 with the United St~.
T
April 18, 2002
Ms. Dory A. Dunlap
98 Locust Street
Shippensburg, PA 17257
Re:
Discover Bank vs.
Dory A. Dunlap
CCP Cumberland County
Civil Action-Law
No. 02-1420
Dear Ms. Dunlap:
Enclosed please find a true and correct copy of a Civil Action
Complaint in regard to the above matter, the original of which
was filed with the court on April 8, 2002.
Please be guided accordingly.
Very truly yours,
ES/kd
Enclosure
CERTIFIED MAIL
RETURN RECEIPT REQUESTED
EDWARD STOCK
THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS A/q ATTEMPT
TO COLLECT A DEBT ~uND ANY INFORMATION OBTAINED WILL BE USED FOR
THAT PURPOSE.
EDWARD STOCK, ESQUIRE
I.D.#13657
18th Floor
1608 Walnut Street
Philadelphia, Pa. 19103
(215) 893-9322
Attorney for Plaintiff
DISCOVER BANK, ISSUER OF
DISCOVER CARD BY ITS AGENT
DISCOVER FINANCIAL SERVICES,
INC.
P.O. Box 6011
Dover, DE 19903-6011
Plaintiff
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL ACTION-LAW
DORY A. DUNLAP
98 Locust Street
Shippensburg, PA 17257
Defendant (s)
NO. 02-1420
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Enter Judgment by Default in favor of the
Plaintiff, Discover Bank, issuer of Discover Card by
its agent Discover Financial Services, Inc., and
against the Defendant(s), Dory A. Dunlap, for failure
to Answer the Civil Action Complaint. Assess
Plaintiff's damages in the sum of $3,5 8.07 in
accordance with the prayer of th
I hereby assess damages in the sum of $3,548.07 in
favor of the Plaintiff, Discover Bank, issuer of
Discover Card by its agent Discover Financial Services,
II/C. ~
as above.
and against the Defendant(s), Dory A. Dunlap,
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF PHILADELPHIA:
EDWARD STOCK, ESQUIRE being duly sworn according to law,
deposes and says:
(a) That the Defendant(s) is/are not in the Military or
Naval Service of the United States or its Allies, or otherwise
within the provisions of the Soldiers' and Sailors' Civil Relief
Act of Congress of 1940 as amended;
(b) That Defendant, Dory A. Dunlap, is approximately 40
years of age, resides at 98 Locust
17257, and is self-employed·
(c) That Defendant
approximately
Street, Shippensburg, PA
Affiant has
, is
years of age, resides at
, and is a housewife.
ascertained the foregoing information by
personal investigation and makes this Affidavit in due authority,
and he understands that the statements herein are made subject to
· Sec. 4904, rela 'ng t~o unsworn
falsification to authorities.
DISCOVER BANK, ISSUER OF
DISCOVER CARD BY ITS AGENT
DISCOVER FINANCIAL SERVICES,
INC.
vs.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
CIVIL ACTION-LAW
DORY A. DUNLAP NO. 02-1420
Defendant(s)
CERTIFICATION UNDER PA. R.C.P. 237.1
EDWARD STOCK, ESQUIRE, Attorney for Plaintiff,
Discover Bank, issuer of Discover Card by its agent
Discover Financial Services, Inc., certifies that he
sent a copy of the attached Notice on May 21, 2002
by regular mail, to the Defendant(s) at the address at
which the Defendant(s) was/were served with a copy of
the Complaint by Certified Mail as indicated by the
Certificate °f Service fiiii~
DATE:
DIS~,OD.VER BANK, ISSUER OF DISODVER CARD BY
i~'AG~lV~ DISODVER FINANCIAL SERVICES, INC.
Plaintiff
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
vs.
DORY A. DUNLAP
TO:
Defendant(s)
Dory A. Dunlap
98 LOCUst Street
Shippensburg, PA 17257
NO. 02-1420
DATE: May 21, 2002
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO TAKE ACTION
REQUIRED OF YOU IN THIS CASE. UNLESS YOU ACT WITHIN 10 DAYS
FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST
YOU WITHOUT A HEARING AND YOU MAY LOST YOUR PROPERTY OR
OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER
AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE,
GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE
YOU CAN GET LEGAL HELP:
Court Administrator
One Courthouse 'Square
4th Floor
¢arlisle, PA 17013
(717) 240-6200
AVISO IMPORTANTE
USTED ESTA EN REBELDIA PORQUE HA FALLADO EN TOMAS LA ACCTION
EXIGIDA DE SU PARTE EN ESTE CASO. A MENOS DE QUE USED ACTUE
DENTRO DE DIEZ DIAS DE LA FECHA SE ESTE AVISO, SE PUEDE REGISTRAR
EN SENTENCIA CONTRA USED, SIN EL BENEFIClO DE UNA AUDIENClA
Y PUEDE PERDER SU PROPOEDAD O OTROS DERECHOS IMPORTANTES.
USTED DEBE LLEVAR AVISO A UN ABOGADO ENSEGUIDA. SI USED NO
TIENE UN ABOGADO Y NO PUEDE PAGAR POR LOS SERVIClOS DE UN
ABAGADO, DEBE COMUNICARSE CON LA SIGUIENTE OFICINA PARA
AVERIGUAR DONDE PUEDE OBTENER AYUDA LEGAL:
SERVICIO DE REFERENCIA LEGAL
Court Administrator
One Courthouse, Square ~
4th Floor
C~rlisle, PA 1 701 3
(717) 240-6200
EDWARD S
18th Floor
1608 Walnut Street
Philadelphia, Pa. 19103
(215) 893-9322