Loading...
HomeMy WebLinkAbout06-1883 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. ESTEBAN FIGUEROA Defendant No: 0L - /PP3 alu,b 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 05067827 C A Pit WLG IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No ESTEBAN FIGUEROA 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: ESTEBAN FIGUEROA 196 N QUEEN ST SHIPPENSBURG, PA 17257 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011002240760538 . 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 15, 2006 , in the amount of $2407.50 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 $300.00 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 , ESTEBAN FIGUEROA INDIVIDUALLY , in the amount of $2407.50 with interest at the legal rate of 6.0006 per annum from date of judgment plus attorneys' fees of $300.00 , and costs. James C. WELTMAN, 436 Se ei Pitts r (412);'4 FAX : A 1 050678 7 J This law firm is a debt collector attem ing our client and any information obtained will arm ro t,4 5 4 WEINBERG & REIS CO., L.P.A hth Avenue, Suite 2718 3h, PA 15219 1-7955 338-7130 C A Pit WLG to collect this debt for be used for that purpose. new balance mint-u- pay".' due DISC-..?.)VER $0.00 $412.00 I-- CARD payment due date February 27, 2006 n. 4 r?. :. 31 SDSN6A01 0006747 ESTEBAN FIGUEROA 196 N QUEEN ST 4°XHIBIT SHIPPENSBURG PA 17257-1 account number 6011 0022 4076 0538 enter amount enclosed below Use your card with confidence--Discover Card ranked #1 in Fraud Protection Services among the largest card issuers by Javelin Strategy & Research in hs 2005 report. 15251 WILMINGTON DE 19886-5251 Address or telephone change? Pease print change in the space above, or go to Discovercantcom. 00000601100224076053800000000000000004120C Discover Card Account Summary Closing Date: January 31, 2006 page 1 of 1 account number payment due date minimum payment due credit limit credit available cash credit limit cash credit available 6011 0022 4076 0538 February 27, 2006 $412.00 $1,600.00 $-807.00 $800.00 $0.00 Cashback Bonus® previous balance $2,407.50 payments and credits - 2,407.50 purchases + 0.00 cash advances + 0.00 balance transfers + 0.00 FINANCE CHARGES + 0.00 new balance = $0.00 Opening Cashback Bonus Balance New Cashback Bonus Earned Cashback Bonus Balance Available to Redeem $ 0.00 + 0.00 $ 0.00 $ 0.00 Cashback Bonus® Anniversary Date: November 3 Transactions trans, post date date Payments and Credits Jan 31 Jan 31 INTERNAL CHARGE-OFF $ -2,407.50 Average Daily Daily Periodic Balances Rates current billing period: 28 days Nominal ANNUAL Transaction ANNUAL Periodic Fee PERCENTAGE PERCENTAGE FINANCE FINANCE RATES RATES CHARGES CHARGES 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 isbtV t± - t IC`s (Name) kcrto -j &?y of Discover Financial Services LLC , plaintiff herein, that (Title) J (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. /14 -?? Signature) WWR # 5067827 ESTEBAN FIGUEROA 6011002240760538 77 11 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNT 'f, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 06-1883 CIVIL TER vs. PRAECIPE FOR DEFAUL JUDGMENT ESTEBAN FIGUEROA Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD THIS PARTY: WILLIAM T. MOLCZ N, 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#05067827 Judgment Amount $ 2,707 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT F R 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. ESTEBAN FIGUEROA Defendant TO THE PROTHONOTARY: Civil Action No. 06-1883 PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, ESTEBAN FIGUEROA Answer, in the amount of $2,707.50 computed as follows: Amount claimed in Complaint $2,407 Interest from date of judgment at the legal interest rate of 6% per annum Attorney's fees $300 TOTAL $2,707 I hereby certify that appropriate Notices of Default, as attached have R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, By: ?1/ / WILLIAM T. MOL ZAN PA I.D.#47437 Weltman, Weinberg & i 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05067827 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7'" Avenue, And that the last known address of the Defendant is: 196 N QUEEN ST., SHIPPEN; TERM named, in the default of an mailed in accordance with PA & REIS CO., L.P.A. Co., L.P.A. PA 15219 17257. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff ESTEBAN FIGUEROA Defendant(s) IMPORTANT NOTICE TO: ESTEBAN FIGUEROA 196 N QUEEN ST SHIPPENSBURG,PA 17257 Date of Notice: /rG?s WWR#: 05067827 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED # 0?kj??' ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE INJWRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW PROVIDE YOU WITH INFORMATION ABOUT HIRING A IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 3ET FORTH AGAINST YOU. 'HIS NOTICE, A BRING AND YOU MAY )U SHOULD TAKE THIS i A LAWYER, GO TO OR THIS OFFICE CAN R. OFFICE MAY BE ABLE TO MAY OFFER LEGAL NO FEE. BY: JAME i ARMBRODT, SQUIRE PA D. #42524 WEL WEINBERG & REIS CO., L.P.A. 27 8iKOPPERS BLDG 436 7TH AVE. PI TrSBURGH, PA 15219 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Case no: 06-1883 CIVIL TERM Plaintiff NON-MILITARY AF IDAVIT VS. ESTEBAN FIGUEROA Defendant The undersigned, who first being duly sworn, according to law, deposes ano states as follows: That he/she is the duly authorized agent of the Plaintiff in the within Affiant further states that the within Affidavit is made pursuant t{O 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 beli f that the Defendant, ESTEBAN FIGUEROA 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, ESTEBAN FIGUEROA is not i the military service. Further Affiant sayeth naught. SWORN TO AND SCRIBED in my presence this ?. 2006 , 3 day Notenel J. Kely, h This law firm is a debt collector attempting to collect this debt for our client and used for that purpose. information obtained will be Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 MAY-22-2006 09:40:51 C Last Name First/Middle Begin Date Active Duty Status Service/Agency FIGUEROA Based on the information you have furnish d, the DMDC does not possess any information indicating that the ndividual is currently on active duty. Upon searching the information data banks of the Department of Defense empower Data Center, based on the information that you provided, the above is the current status of the ndividual 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 maintains the Defense Enrollment and Eligibility Reporting System (D] official source of data on eligibility for military medical care and other The Department of Defense strongly supports the enforcement of the Sen [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailo DMDC has issued hundreds of thousands of "does not possess any inform individual is currently on active duty" responses, and has experienced a si individual referenced above, or any family member, friend, or representat the individual is on active duty, or is otherwise entitled to the protections encouraged to obtain further verification of the person's active duty status Military Service via the "defenselink.mil" URL provided below. If you he active-duty and you fail to obtain this additional Military Service verifical may be invoked against you. If you obtain further information about the person ( e.g., an SSN, name), you can submit your request again at this Web site and we query. This response reflects current active duty status only. For historical Military Service SCRA points-of-contact. See: hUp://www_d(zfQrkaelink.mil/faa/nis/PC09$LDR.html WARNING: This certificate was provided based on a name and Social .merit of Defense that database which is the ity systems. -members Civil Relief Act Civil Relief Act of 1940). ion indicating that the 11 error rate. In the event the asserts in any manner that the SCRA, you are strongly contacting that person's evidence the person is on n, provisions of the SCRA accuracy of DOB, a middle ide a new certificate for that please contact the number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 1 5/22/2006 Request for Military Status Page 2 of 2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID. DCDVUDZLHF https://www.dmde.osd.mit/scra/owa/scra.prc_Select 5/22/2006 -4s. ?l .a .,n1Y1 ? v ? r }iT IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 06-1883 CIVIL TERM ESTEBAN FIGUEROA Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order o Judgment was entered against you on,st .ZCCX. (xx) Assumpsit Judgment in the amount of $2,707.50 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license a d/or registration will be suspended by the Department of Tran portation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary n By: ESTEBAN FIGUEROA 196 N QUEEN ST SHIPPENSBURG,PA 17257 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7" A enue, Pittsburgh, PA 15219 1-888-434-0085 SHERIFF'S RETURN - REGULAR CASE NO: 2006-01883 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS FIGUEROA ESTEBAN RONALD HOOVER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon FIGUEROA ESTEBAN the DEFENDANT , at 1145:00 HOURS, on the 12th day of April 2006 at 196 N OUEEN STREET SHIPPENSBURG, PA 17257 by handing to JOHN VELLA, ROOMMATE ADULT IN CHARGE 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 18.48 Affidavit .00 Surcharge 10.00 .00 46.48 Sworn and Subscribed to before me this /q4? day of "I a" G A. D. So Answers: R. Thomas Kline 04/13/2006 WELTMAN WEINBERG REIS By: Deputy Sheriff Prothonotary IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. ESTEBAN FIGUEROA Defendant PNC BANK, Garnishee, DEFT: ESTEBAN FIGUEROA 196 N QUEEN ST SHIPPENSBURG,PA 17257 No. 06-1883 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. 447437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05067827 GARNISHEE: PNC BANK 105 NOBLE BLVD., CARLISLE, PA. 17013 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 06-1883 CIVIL TERM ESTEBAN FIGUEROA Defendant PNC BANK, 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 Esteban Figueroa, Defendant 3. against PNC Bank, Garnishee 4. Judgment Amount Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): WELTMAN, By: William T. olczan PA I.D. #47437 WELTMAN, WE BE 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05067827 $ 2,707.50 $ 66.76 $ 2,774.26 & REIS CO., L.P.A. & REIS CO., L.P.A. 44, vi 1 v tyj co 0 ? ?i WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-1883 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From ESTEBAN FIGUEROA, 196 N. QUEEN ST., SHIPPENSBURG, PA 17257 (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 PNC BANK, 105 NOBLE BLVD., CARLISLE, PA 17013 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 $2,707.50 Interest $66.76 Atty's Comm % Atty Paid $128.98 Plaintiff Paid Date: NOVEMBER 6, 2006 (Seal) L.L. $.50 Due Prothy $1.00 Other Costs C is R. Long, P notary 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 DISCOVER BANK PLAINTIFF, CIVIL DIVISION NO.:06-1883 ANSWERS TO INTERROGATORIES IN ATTACHMENT AND NEW MATTER vs. Filed on behalf of PNC Bank, National Association ESTEBAN FIGUEROA DEFENDANT, and Code: PNC BANK, N.A. GARNISHEE. Joel B. Gold, Esquire Counsel for PNC Bank, National Association Pa. I.D. #42090 PNC Bank, National Association Firm #862 One PNC Plaza, 21" Floor 249 Fifth Avenue Pittsburgh, Pennsylvania 15222-2707 (412) 762-2801/4334 (facsimile) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA Discover Bank Plaintiff, NO.:06-1883 vs. Esteban Figueroa Defendant, and PNC Bank, N.A. Garnishee. ANSWERS TO INTERROGATORIES IN ATTACHMENT AND NEW MATTER AND NOW, PNC Bank, N.A the Garnishee ("Bank"), files this response including New Matter stating as follows 1. Yes. See New Matter. 2 -12 See New Matter. NEW MATTER 13. Paragraphs 1 through 12 are incorporated herein by reference. 14. PNC Bank, N.A., Garnishee, files this New Matter in accord with Pa. R.C.P. 3145(b)(3) and 42 Pa. C.S.A. §2503. 15. Through a deposit agreement with its customer PNC Bank is to be paid its $100.00 Legal Process service charge, with respect to which the Bank claims a right to set off. R 16, In the present case, after deducting the $100 service charge the Bank has an account balance of $37.76 owed to the defendant. WHEREFORE, PNC Bank, N.A. admits owing a debt of $37.76 to defendant. Respectfully submitted, PNC BANK, NATIONAL ASSOCIATION Joel old Lit/garnishee answers/Not AC.figueroa120406.doc i)tt--bb-&UUb 10:02 RAC GARH ACCTS SERVICES 412 7(S2 5176 P.01 VERIFICATION T'he undersigned, Carol M. Williams, an authorized representative; for hNC Bank, NA, does hereby verify that the foregoing Answers To Interrogatories in Attachment and New Matter is true and correct to the best of my knowledge, information and belief. This Verification is made subject to penalties of 18 Pa.C.S.A. §4904 relating to unsworn falsification to authorities. Carol M. Williams Dated: / A • G - 06' r-? ?? ?? -? ? ?-- ?,.. =? - K ? `, t ... ff??? rx ? ?'? Sr. ? -y-i i"E'? . ? .r?L`? ..? ', { ?? -s - r:+ < 1 •--sr? -. ? t? ' ? y;,? r --? SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-01883 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND DISCOVER BANK VS FIGUEROA ESTEBAN And now DAVID MCKINNEY ,Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0015:15 Hours, on the 15th day of November , 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of: the within named DEFENDANT , FIGUEROA ESTEBAN in the hands, possession, or control of the within named Garnishee PNC BANK 105 NOBLE BLVD CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to VIOLA ROELKE (ASST MGR) 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 Her Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 .00 - 00 Sworn and Subscribed to before me this day of So answ rs- R. Thomas Kling Sheriff of Cumberland County 11/17/2006 By Deputy Sheriff A.D IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. ESTEBAN FIGUEROA Defendant PNC BANK Garnishee No.: 06-1883 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE & END AS TO THE GARNISHEE PNC BANK ONLY 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#05067827 A IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No.: 06-1883 CIVIL TERM ESTEBAN FIGUEROA Defendant PNC BANK Garnishee PRAECIPE TO SETTLE DISCONTINUE AND END AS TO THE GARNISHEE, PNC BANK, ONLY TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue and End the above captioned matter as to Garnishee, PNC BANK, only, upon the records of the Court and mark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. root PA I.D # 524 WELT AN, EINBERG & REIS CO., L.P.A. 271.8 K pper uilding 436 S ent Avenue Pittsb ng PA 15219 (412 4 -7955 067827 Sworn to and subscribe Before me the 1&11 Day of DECE BEr 2006 "NOTARY PUB 'KC COMMONW-CALTH OF PENN No* rini Seal Wayne A. Jones, ?'4otary Public Fy ity Of Pittsburc:-4, t?. i,gheny County Commission Expifes June 29, 2010 Member. Pennssv?n!U is.?ci?ti?n of Notaries n ? Q O ?o .?J O C ? -? ? ?? 0 r-? G '' ?-" '? ..- ? ? `?, c!? ?' ?:? t W ? a ? ? c ? ;E? ?, R. Thomas Kline, Sheriff;. Who being- dulg-?' v according to law, states this Writ is returned ABANDONED, no action`tAk6ri in six months. Sheriff's Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Misc. Surcharge Levy Post Pone Sale Certified Mail Postage Garnishee TOTAL 2006 NOV -o A 4: I -I 18.00 1.66 .50 1.00 4.40 30.00 20.00 Advance Costs: 150.00 Sheriff's Costs 84.56 65.44 Refunded to Atty on 07/17/07 9.00 84.56 v" ,111 So Answers; -:eo ? R. Thomas Kline, Sheri ff By ?-FJ C? 0 r W L£bLt, •oN QI lmo0 autazdnS S96L-b£h-Zit, :auogdalaZ 33I.LNlV'Id :.toj Aauaow 61ZSi Vd `H'9HaE[S.L.LId dfIN3AV H,LNaAdS 9£fi ONII ililag Sdaddox 8ILZ 'd'd.,I `'03 SI3HI V 9dala laM `NVNI.L'IdM :ssaipPV fgnda(l :Ag L-4m?-oluojd `8uo'I slso0 lagl0 00' 15 Aipozd on(i AlWVd ONI.LM61H (Oros) 9002 `9 IIHEI HAON :OWG Pled 33RUMd 86'8ZIS P1ed X:RV % U-Ruo0 s,Klld 9L'99S Isatalul OS'$ •7.7 0S'L0L`ZS anQ IunoutV •paleis anogz se pautofua si pule QaqsiuivS L, se pappe uaaq seq oqs/aq Iegl .taq/tuiq Xjjjou of paloa.np are noX `aagsitue8 pouteu a uegl zaglo Quo iue jo uotssassod otg ut puno3 st luouzgoeiie of loafgns ue uodn patAal lou (s)Iuepuojop aql jo ffliadotd jI (£) `joajagl 8utsodsip osLvaaglo to (s) luepuajap agi3o A4zadoad Cue Suuantlop uio4 put, (s) Iuepuajop aql jo lunoooe aip joj so of Igop Cue SulARd tuotl poutofua si (s)a3gsture8 aqI (q) `.ponsst uaaq seq luauuloeile ue (e) :Irgl (s)aagsitue8 aqI Aj!lou of put smolloi se (S)adHSINUVJ £IOLi Vd `?'ISI'RiVO `'QA'Ig ?'IgOl?i SOi `?II?iVg 01,id 30 uotssassod oql ut uodn patAal iou (s)luepua3ap aqi jo fipodoid aqi queue of paloanp osle aze noA (Z) Ilas of pue(s) Iuepua;ap oql jo livado.id otp uodn AAal oI paloaztp aze noA (I) LSZLI Vd `OIIIIgSN3ddIHS `'ZS Ndgfla 'I\I 961 `V02IdfI0I3 NVgd.LSd tu0JJ (s) 331Iu1eId `XNVg HaAOjSIQ anp sisoo pue Isa.zalu? `lgap aql Xjsiles oZ :A,LNIl00 QNV'M2[ff aJ 30 ddFUHS dH1 OZ MV'I - NOIlDV 'IAIO IIA?:) £881-90 ON (axv- mgwm 30 A.LNf10o (VlX'VA'IASNNad 90 HJ,-l'V9MNOWWO3 d?IIflbSH `NVZJ'l0W 'Z LJ7I'I'IIM OUIeN T \TTT/TTT'116-7T T47 Inln17V_ \T/%TT /1'1rtT<?rr .rte Try:.. WELTMAN, WEINBERG & REIS CO., L.P.A. BY: Sarah E. Ehasz, Esquire Attorney for Plaintiff(s) I.D. No.86469 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 = ? Fax: 412.434.7959 ; -° -?- File # 5067827 DFO ` -- 3 ? DISCOVER BANK Plaintiff "X- C) = = em.: r { CUMBERLAND County 5 Court of Common Pleas -t vs. NO. 06-1883 CIVIL TERM ESTEBAN FIGUEROA Defendant(s) PRAECIPE FOR SATISFACTION OF JUDGMENT TO THE PROTHONOTARY: Please kindly Satisfy the Judgment of the above-captioned matter upon the records of the Court and mark the cost paid. Sarah E. Ehasz, Esquire Attorney for Plaintiff Sworn to and subscribed Before me the 7 day NkfrA-RY P LIC WELTMAN, WEINBERG & REIS CO., L.P.A. By 2011 COMMONWEALTH OF PtNNSYLVANIA Notarial Seal Wayne A. Jones, Notary Public City of Pittsburgh, Allep3heny County Ply Commission Expires June 29, 2014 M +r+her: Pennovlvenia Amclatlon of Notaries ? a S 10 S1 St