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'
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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
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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
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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