HomeMy WebLinkAbout06-1783i
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS.
CYNTHIA B YERKES
Defendant
NO: O to - 1 713 Ct I e -
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
05026697 C A Pit WLG
I
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
CYNTHIA B YERKES
Defendant
Civil Action No 0 -/ 1" Ccc.. ( l ,e.,.,
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 HE11P.
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:
CYNTHIA B YERKES
328 W SOUTH ST
CARLISLE, PA 17013
3. Defendant applied for and received a credit card issued by
Plaintiff bearing the account number 6011002110768512 . 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 March 14, 2006 , in the amount of
$5090.04 .
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 $500.00
i
I
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 , CYNTHIA B YERKES INDIVIDUALLY , in the amount of
$5090.04 with interest at the legal rate of 6.000% per annum from date
of judgment plus attorneys' fees of $500.00 , and-cost
t V r r
James C Warmbrodt,42524
WELT , WEINBERG & REIS CO., L.P.A.
436 'e enth Avenue, Suite 2718
Pit s urgh, PA 15219
(41 434-7955
F 412-338-7130
05 6697 C A Pit 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.
I
payment due date $ ??
February 3, 2006
a a?? 7
04 SDSN6A01 0001923
CYNTHIA YERKES
328 W SOUTH ST
CARLISLE PA 17013-2826
Address or telephone change? Please print change in the space above,
or go to Dismvercard.com.
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.
PO BOX 15251 111.111 loll 11 Sigel 111 111111
WILMINGTON DE 19886-5251
II IIIIIIII, I III III III III III I III III I III III lltl III loll III IOI
000006011002110768512050900400000000067500
------ -- - ------- --------------------- -
Discover Platinum Card Account Summary Closing Date: January 4, 2006 page 1 of t
previous balance $4,977.64
account number 6011 0021 1076 8512 payments and credits - 0.00
payment due date February 3, 2006 purchases + 39.00
j minimum payment due $675.00 cash advances + 0.00
credit limit $5,100.00 - -
credit available $0.00 balance transfers + 0.00
;cash credit limit $1,300.00 FINANCE CHARGES + 73.40
cash credit available $0.00 new balance = $5,090.04
E-VIF
r.xKIBIT
,t A,t
---- ------ --- ------------ - -- ----- - ------- ----- - -- --------------
Cashbaek 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: September 4
trans. post
date date
,Other/Miscellaneous Jan 4 Jan 4 LATE FEE
-- --------------------
Average Daily
Daily Periodic
Balances Rates
current billing period: 31 days
Purchases $5013.05 0.04723%
Cash Advances $0 0.0575t%
$ 39.00
Nominal ANNUAL Transaction
ANNUAL Periodic Fee
PERCENTAGE PERCENTAGE FINANCE FINANCE
RATES RATES CHARGES CHARGES
1724% V 1724% $73.40 none
20.99% F 20.99% $0 $0
VERIFICATION
The undersigned does hereby verify subject to t e p 7 ? (, allie7/1(, f 18 P .C.S. §4904 relating to
unworn falsification to authorities, that he/she is 1 (
Name)
of? 1? ???? Yom' V ? yA !? ?? plaintiff herein, that
y
(Title) (Company)
he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint
in Civil Action are true and correct to the best of his/her knowledge, information and belief.
WWR # 5026697
CYNTHIA B. YERKES
6011002110768512
F.. s -
(1
0
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
CYNTHIA B YERKES
Defendant
No. 06-1783
PRAECIPE FOR DEFAULT JUDGMENT
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
WILLIAM T. MOLCZAN, ESQUIRE
PA I.D.447437
Weltman, Weinberg & Reis Co., L.P.A.
2718 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#05026697
Judgment Amount $ 5,590.04
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.
CYNTHIA B YERKES
Defendant
TO THE PROTHONOTARY:
Civil Action No. 06-1783
PRAECIPE FOR DEFAULT JUDGMENT
Kindly enter Judgment against the Defendant, CYNTHIA B YERKES above named, in the default of an
Answer, in the amount of $5,590.04 computed as follows:
Amount claimed in Complaint $5,090.04
Interest from date of judgment
at the legal interest rate of 6% per annum
Attorney's fees $500.00
TOTAL $5,590.04
I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA
R.C.P. 237.1 on the dates indicated on the Notices.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By.
WILLIAM T. MOLCZA ESQUIRE
PA I.D.#47437
Wellman, Weinberg & Reis Co., L.P.A.
2718 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#05026697
Plaintiffs address is:
c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7" Avenue, Pittsburgh, PA 15219
And that the last known address of the Defendant is: 328 W SOUTH ST
CARLISLE,PA 17013
IN THE COURT(3F?-014MON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
CYNTHIA B YERKES
Defendant
06-1783
IMPORTANT NOTICE
TO:
Cynthia B Yerkes
328 W South St
Carlisle,Pa 17013 Ln ?
Da te of Notice: /
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE
PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS
TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS
NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR
PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF
'YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE
TO FIND OUT WHERE YOU CAN GET LEGAL HELP. -
LAWYER REFERRAL SERVICE
Cumberland County Bar Association
32 South Bedford Street
Carlisle, PA 17013
(717) 249-3166
WELTMAN, WEINBEI$D.&-?CO., L.P. .
By. - Y K I/
James C. A'armbrodtf Esquire
PA I.D. 524
WEL N, WEINBERG & REIS CO., L.P.A.
2718 o pers Building
436,'Sev nth Avenue
Pit{sb eh. PA 15219
#05026697
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No. 06-1783
CYNTHIA B YERKES
Defendant
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the following
Order r Judgment was entered against you
on i Jlt I Q-A'->&
(xx) Assumpsit Judgment in the amount
of $5,590.04 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
(xx) Default
( ) Verdict
( ) Arbitration
Award
Prothonotary
By:
PROTHONOTARY (J 94DC-PUTY)
CYNTHIA B YERKES
328 W SOUTH ST
CARLISLE,PA 17013
Plaintiffs address is:
c/o Weltman, 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
Case no: 06-1783
Plaintiff
vs.
CYNTHIA B YERKES
Defendant
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, CYNTHIA B
YERKES 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, CYNTHIA B YERKES is not in the military service.
Further Affiant sayeth naught.
I l?
AFFIANT
, ) Ar?
SWORN UBSCRIBED in my presence this day
of
,•
Wend ?? ' +a_.._..
N?eARY PUBLIC
ry Ot Pittsburgh, All
A7y Corromission E ztjheny County i
??e? F._„` ><PiresJUly 75,1ppg
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 Servicemembers Civil Relief Act
Page 1 of 2
JUN-08-2006 11:38:22
< Last Name First/Middle Begin Date Active Duty Status Service/Agency
YERKES 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, based
on the information that you provided, the above is the current status of the individual 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 Servicemembers 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 strongly
encouraged to obtain further verification of the person's active duty status by contacting that person's
Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on
active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA
may be invoked against you.
If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle
name), you can submit your request again at this Web site and we will provide a new certificate for that
query.
This response reflects' current active duty status only. For historical information, please contact the
Military Service SCRA points-of-contact.
See: 4ttR;//wwwdefenseti?nk.mil/faa/nis/PC09SLDR html
WARNING: This certificate was provided based on a name and Social Security number (SSN) provided
https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 6/8/2006
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SHERIFF'S RETURN - REGULAR
CASE NO: 2006-01783 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DISCOVER BANK
VS
YERKES CYNTHIA B
DAVID MCKINNEY
, Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
YERKES CYNTHIA B the
DEFENDANT , at 1508:00 HOURS, on the 31st day of March 2006
at 328 W SOUTH STREET
CARLISLE, PA 17013
CYNTHIA YERKES
by handing to
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:
Docketing
Service
Affidavit
Surcharge
So Answers:
18.00
4.40
.00
10.00 R. Thomas Kline
.00
32.40 04/03/2006
WELTMAN WEINBERG REIS
Sworn and Subscribed to before
me this /Qk" day of
?IAev c:1-U'DLr A. D.
By:
Deputy Sheriff
Prothonotary
\1
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
CYNTHIA B YERKES
Defendant
MEMBERS FIRST FCU,
Garnishee,
No. 06-1783 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#05026697
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No. 06-1783 CIVIL TERM
CYNTHIA B YERKES
Defendant
MEMBERS FIRST FCU, "
Garnishee
PRAECIPE FOR WRIT OF EXECUTION
TO THE PROTHONOTARY:
Kindly issue a Writ of Execution in the above matter...
1. directed to the Sheriff of Cumberland County:
2. against Cynthia B. Yerkes, Defendant
3. against Members First FCU, Garnishee
5,590.04 -? ?359[?. p?f
4. Judgment Amount $
Less payments of -(2,000.00)
Interest $ 92.57
Costs $
SUBTOTAL: $ 3,682.61
Costs (to` be added by Prothonotary): $
WELTMAN, WEINBERG & REIS CO., L.P.A.
By: t
1J14-
WilliiaZTT. Molczan, Esqu'
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#05026697
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-1783 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s)
From CYNTHIA B. YERKES, 328 W SOUTH ST., CARLISLE, PA 17013
(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, 1166 WALNUT BOTTOM RD., CARLISLE, PA 17015
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 $3590.04
Interest $92.57
Atty's Comm %
Atty Paid $114.90
Plaintiff Paid
Date: NOVEMBER 15, 2006
(Seal)
L.L. $.50
Due Prothy $1.00
Other Costs
Curtis 0?.Long, P?r tary
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
VS.
CYNTHIA B YERKES
Defendant
and
MEMBERS FIRST FCU
Garnishee
No. 06-1783 CIVIL TERM
ARScuers 4c
INTERROGATORIES IN ATTACHMENT
MEMBERS FIRST FCU
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#05026697
J
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS.
CYNTHIA B YERKES
Defendant
and
MEMBERS FIRST FCU
Garnishee
Civil Action No.: 06-1783 CIVIL TERM
TO: MEMBERS FIRST FCU Suggested Reference No.: XXX-XX-3353
1166 WALNUT BOTTOM RD., RE: CYNTHIA B YERKES
CARLISLE, PA. 17015 328 W SOUTH ST.,
CARLISLE,PA. 17013
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, she 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.
J
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 op any negotiable or other written instrument, or did he claim that you owed him any money
or were liable to him for any reason?
I\U)
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.
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. v 9j?S - A o ,oc#?
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.
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?
NC's
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?
NO,
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?
KD
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.
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 1 I is in the affirmative, describe the amount or nature,
fair market value and present location of each of such payments and properties.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By.
William T. Molc , Esqu'
PA I.D. #47437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#05026697
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SHERIFF'S RETURN - GARNISHEE
CASE NO: 2006-01783 P
COMMONWEALTH OF PENNSLYVANIA
COUNTY O1? CUMBERLAND
DISCOVER BANK
VS
YERKES CYNTHIA B
And now RICHARD SMITH
,Sheriff or Deputy Sheriff of
Cumberland County of Pennsylvania, who being duly sworn according
to law, at 0014:50 Hours, on the 4th day of December , 2006, attached
as herein. commanded all goods, chattels, rights, debts, credits, and
moneys of the within named DEFENDANT
hands, possession, or control of the within named Garnishee
MEMBERS FIRST FCU 1166 WALNUT BOTTOM ROAD
CARLISLE, PA 17013
Cumberland County, Pennsylvania, by handing to
ERIC HESS (ASST. MGR)
personally three copies of interogatories together with 3
and attested copies of the within WRIT OF EXECUTION
the contents there of known to His .
Sheriff's Costs:
Docketing .00
Service .00
Affidavit .00
Surcharge .00
.00
4 0 0
Sworn and Subscribed to
before me this day of
in the
true
and made
So answe
R. Thomas Kline
Sheriff of Cumberland County
12/05/2
By
A.D
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
CYNTHIA B YERKS
Defendant
MEMBERS FIRST FCU
Garnishee
No. 06-1783 CIVIL TERM
PRAECIPE FOR SATISFACTION OF
JUDGMENT AS TO ALL PARTIES
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
James C. Warmbrodt
PA I.D #42524
William T. Molczan, Esquire
PA. I.D.447437
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#05026697
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
CYNTHIA B YERKS
Defendant
MEMBERS FIRST FCU
Garnishee
Civil Action No. 06-1783 CIVIL TERM
PRAECIPE FOR SATISFACTION OF JUDGMENT
AS TO ALL PARTIES
TO THE PROTHONOTARY:
Please kindly Satisfy the Judgment of the above captioned matter upon the records of the Court and
mark the cost paid as to ALL PARTIES.
WELTMAN, WEINBERG & REIS CO., L.P.A.
By:
James C. r brodt
PA I.D # 252
William;`T. M lczan, Esquire
PA.1.R:#474 7
WELTMA , WEINBERG & REIS CO., L.P.A.
2718 Kop ers Building
436 Seve th Avenue
Pittsburgh, PA 15219
(412)1434-7955
W W R#05026697
Sworn to and subs ribed
Before me the <?
Day of JANUA Y,. 07
NOT RY PUB
WNWEALTH OF PENNSYLVAWA_
Notarial Seal
Wayne A. Jones, Notary Public
C?ty OF Pittsburgr1, aJlegheny County
bly Commission Expires June 29, 2010
Member, Pennstlvania Association of Notaries
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WRIT OF EXECUTION and/or ATTACHMENT
COMMONWEALTH OF PENNSYLVANIA)
COUNTY OF CUMBERLAND)
NO 06-1783 Civil
CIVIL ACTION - LAW
TO THE SHERIFF OF CUMBERLAND COUNTY:
To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s)
From CYNTHIA B. YERKES, 328 W SOUTH ST., CARLISLE, PA 17013
(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,1166 WALNUT BOTTOM RD., CARLISLE, PA 17015
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 $3590.04
Interest $92.57
Atty's Comm %
Atty Paid $114.90
Plaintiff Paid
Date: NOVEMBER 15, 2006
(Seal)
L.L. $.50
Due Prothy $1.00
Other Costs
Curti Long, notary
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
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 84.56
Docketing 18.00 65.44
Poundage 1.66
Advertising
Law Library .50
Prothonotary 1.00 Refunded to Atty on 10/24/07
Mileage 4.40
Misc.
Surcharge 30.00
Levy 20.00
Post Pone Sale
Certified Mail
Postage
Garnishee 9.00
f 41"1014-
TOTAL 84.56 So Answers,
• Cn
R. Thomas Kline
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