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Home My WebLink About06-3220IN THE COURT OF COMMON PLEAS OF CUMBERLAND DIVISION MBNA AMERICA BANK, N.A., Plaintiff, No. 10L - vs. ALEKSANDR KOREBA, Defendant. COMPLAINT , PENNSYLVANIA CIVIL ?2'aU (?,Ut ? n FILED ON BE LF OF: Plaintiff COUNSEL OF ECORD OF THIS PARTY: c William T. Mol PA I.D. #47437 WELTMAN,A L.P.A. 2718 Koppers E 436 Seventh Av Pittsburgh, PA (412) 434-7955 W W R #049442 Esquire & REIS CO., 9 Ii IN THE COURT OF COMMON PLEAS CUMBERLAND COUNT Y CIVIL DIVISION MBNA AMERICA BANK, N.A. Plaintiff VS. ALEKSANDR KOREBA Defendant Civil Action PENNSYLVANIA &- -2-220 You have been sued in court. If you wish to defend against the cl ims 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 i 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 r lief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER A ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TEL PHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP Cumberland County Bar Association 32 South Bedford Street Carlisle, Pa 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS OF CUMBERLAND DIVISION MBNA AMERICA BANK, N.A., Plaintiff, VS. ALEKSANDR KOREBA, Defendant. No. Q(D - . COMPLAINT 1. Plaintiff, MBNA America Bank, N.A., is a Delaware. , PENNSYLVANIA CIVIL located in Wilmington, 2. Defendant is an adult individual with a last known add ess of 208 Senate Ave Apt #611, Enola,Pa 17025. 3. On or before December 22, 1998, Plaintiff and Defend t entered into a Cardmember Agreement for a credit card bearing the account number 5490997999465 49. A true and correct copy of the Cardmember Agreement is attached hereto, marked as Exhibit "I" d made a part hereof. 4. The Cardholder Agreement contains a provision to dispute or controversy arising from or relating in any way to the Cardh le by arbitration any claim, r Agreement. 5. Defendant made use of said credit card and has Plaintiff, as of May 24, 2006, in the amount of $20,213.63. 6. Defendant is in default of the terms of the cardholder monthly payments to Plaintiff thereby rendering the entire balance immec 7. Plaintiff avers that the Cardholder Agreement bet Plaintiff is entitled to the addition of finance charges at the rate of balance. 8. Although repeatedly requested to do so by Plaintiff, and/or refused to pay the principal balance, finance charges or any part WHEREFORE, Plaintiff demands Judgment in its favor and Koreba individually, in the amount of $20,213.63„ wjth gontinuing fmanc 6.0% per annum from date of judgment plus costs; or in the alternative, arbitrate this dispute pursuant to the terms contained in the Cardholder Al Respectfully Submitted: By: PA I.D. #47437 WELTMAN, WEIN. 2718 Koppers Buildi 436 Seventh Avenue Pittsburgh, PA 1521 (412) 434-7955 a balance due and owing to ;ment having not made due and payable. the parties provides that per annum on the unpaid has willfully failed Plaintiff. Defendant, Aleksandr charges thereon at the rate of order directing the parties to & REIS CO., L.P.A. .?btr-10"ZUUJ Iut iGUi rn JHLO IMMMUUMMI i _ I rtiA rN, Me. 100 Ugio r, UZ/Id General In this Credit Card Agreem, 'your refer to each and all of credit card issued by us or un This credit Card Agreerp$ Ut of this document and the tern in the Required Federal Disc( accompanying card carrier, wt and made a part hereof. The 'MBNA America" mean MBNA When you accept or use the terms in this Agreement. You before you use it. You consent to and authors affiliates, or its marketing a record any of your telephone sentattves or the representati All capitalized terms rot d meaning as defined in the Re section of your card carrier. From time to time, we mal tion about you including, for tfon. We may share info mat reporting agencies and other among companies afftifateciv that information about you n affiliates, other than informat transactions or experiences b MBNA America affiliate), by u information Sharing, P.O. Box 19850.5342. Please include p phone number and all MBNA If you believe that inamrrau about you or your account has credit reporting agency, write to ReportfngAgencies, P.O. Box 1' 1 9884-705 4. Please include yoi phone number, and account nu Information you believe is inao EX MIT nt, the words -you` and he persons who accept a er an account we hold. he "Agreement') consists is and conditions set forth isures section of the ich is incorporated herein words. -we." -us,"our' and America Bank, N.A. account, you agree to the should sign your card MBNA America, any of its ites to monitor and/or versations with our repre- of any of those companies. ned herein shall have the sired Federal Disclosures g and Sharing obtain updated informa- xample, credit informa- >n about you with credit including merchants, and thus. You may request t be shared among our on pertaining solely to tween you ands f or an sting us at MBNA, Affiliate 5342, Wilmington, DE ur name, address, home imerica account numbers. or incomplete information seen shared by us with a us at: MBNA, Credit 154, Wilmington. DE name, address, home nber, and explain which gate or incomolete. SEP 16 2003 120? PG#.02 ?xr-ID-cuuo iuc ic•uo m aru o iurnnuuiruu rnn nu ouc v? uvoo r, uai1.1 You may use your credit card o purchase or lease goods or services from persons ho honor the card. You may also use your card to obtaf Cash Advances. You may not use a Check Cash Adva ce. or any other Cash Advance, to make a payment on this or any other credit account with us. You may not u e your account for busi- ness or commercial purposes. Certain establishments' ra`y sh your personal checks upon presentment of your card. n the event we are required to pay the amount of a cashed in this way because the check is not paid lo any reason, we will charge your account for a Cash nce in the amount of the check and any processing ch rge we actually incur. If you permit any person to h ve access to your card or account number with the aut orization to make a charge, you may be liable for al charges made by that person including charges for w ich you may not have intended to be liable. The transaction date for Ch Cash Advances and Balance Transfers is the date yo or the person to whom the check is made payable first eposits or cashes-the check. The transaction date for retumed payment fa Bank Cash Advance) is the date hat the corresponding payment posted to your accoun . You may request a stop paym nt on check cash Advances by providing us with t e check number, dollar amount, and payee exactly as tit appear on the Check Cash Advance. Oral and written op payment requests on Check Cash Advances are eff he for six months from the day that we place the stop ment on your account. You may not use a.postdated Cash Advance to obtain credit under your sooount If you do postdate a Check Cash Advance, we may el to honor it upon pre- sentmeni or return it unpaid to t e party which presented it to us for payment, without in a ther case awaiting the date shown on the Check Cash nce. we are not liable to you for any loss or expense in ned by you arising out of the action we elect to take. Repayment You promise to pay us the obtain; this includes all purl SEP 16 2003 12.08 nts of all credit you cash advances, fees, PAGE. 03 SEP-16-000S IM tL:UH rn bHLhb WH4001 rHA nU. due iIw u4jb r. Uq/16 Your account ana rmance una?rges. You may pay the entire amo nt outstanding at any, time. You must pay each mon h at least the minimum payment shown on your mont )y statement. If you over- pay or if a credit balance is oth noise created In your account, we will not pay Inter t on such amounts. Your j payment will be allocated in a anner we determine. In 1 most instances, we will alJ&ate your payments to balances 1 (including new transactions) With lower APRs before I balances with higher APRs. T is will result In new bal- l antes with a lower rate of inte est being paid before any { other existing balances. All yments will be credited to 1 your account for the billing cy le in which each payment is received; however, your avai able credit may not be increased by the amount of th payment until your funds have cleared. Minimum monthly payments can- not be made in advance and yments made in any billing cycle which are greater han the minimum pay- ment due will not affect your c ligation to make subse- quent minimum payments eat month. We can relea; payments not denominated in I.S. dollars or not drawn on a U.S. Bank No payment sh all operate as an accord and satisfaction without the pri r written approval of a senior officer of MBNA America All persons who initially orsubsequently request, accept or use the account are i dividually and together responsible for any outstanding balance, If two or more persons are responsible to pay any outstanding balance. we may refuse to release any o them from liability until all of the unexpired cards outst nding under the account have been returned to us and the balance is paid in full. Reasons for Requiring Immediate Payment You will be in default and wi payment of all amounts you ov any required payment by the P, New Balance Total exceeds you have established a separate Ca. for you, your outstanding Cash your Cash Advance credit limit: by any other terms of this Agrel if you default, unless prohibi can require immediate if: (1 I you fail to make ment Due Date: (2) your credit limit, or if we i Advance credit limit dvance balance exceeds ,r 13) you fail to abide by applicable law, we SEP 16 2003 12:09 PRGE.04 Jtr'lo'cwo IuL Ic•uo m arn.w 111111MUIL111 • i i i i I nA I1V, JVL JI V41 1, U411V can also require you to pay to costs we incur in any collectio sonable attorney's fee if we rel tion to an attorney who is not our failure to exercise any c default does not mean that wt those rights upon later detauli Payment Holidays We may allow you. from tine monthly payment. We will not is available. If you omit a pays and credit insurance premlum your balance in accordance wi, requirement that you make a r month will resume following y ies Made In For If you incur a charge in a ft will be converted by visa Inte international, depending on % u.5. dollar amount in accordi regulations or conversion pro time that the transaction is p. regulations and procedures p conversion rate to be used is market rate or (2) a govern me one day prior to the processir percent in each case. Visa or one percent as compensation Cy conversion service. The cu: effect on the processing date effect on the transaction date A billing cycle begins on the shown on your account's preced and ends on the closing date th account's statement for the cuff Account Fees and Cha Account Fees: The following on your card carrier, are assesse billing cycle in which such charg Fee, (2) if your account is overlir a collection and court proceeding, and a rea- your account for collec- r ur salaried employee. our rights when you ire unable to exercise to time, to omit a y you when this option ant. Finance Charges if any, will accrue on this Agreement. The nimum payment each Ir payment holiday. in Currencies :ign currency, the charge ational or MasterCard Ich card you use, into a :e with the operating dures in effect at the cessed. Currently,-those vide that the currency ter (1) a wholesale -mandated rate in effect date, increased by one asterCard retains this it performing the curren- incy conversion rate In iy differ from the rate in the posting date. y after the closing date g monthly statement appears on your t rnonth. :es, which are set forth as Purchases In the -s accrue: 11) a late it Ieven if fees or StP 16 2003 12:08 PRGE.05 I atr-10 LUUJ Iva IL-VU III JnLLJ IrtIMLMR1 II11I IIV, VVL JV VYJV 1, VVI IV .1 Total to exceed your credit limit on the last day of a billing cycle, an Overlimit Fee i charged to your account as of the day in the billing cycle that your account went over the credit limit; (3) a Return ed Payment Fee if a pay- ment on your account Is return for insufficient funds or for•any other reason, even if it is paid upon subsequent f presentment; (4) a Returned,Ch k Fee if we return a Check Cash Advance unpaidyfot ny reason, even if the Check Cash Advance is paid upo subsequent present- ment; (5) if your account is open or if you maintain an account balance, whether you ha ve active charging privi- leges or not, an Annual Fee. Abandoned Property Charge s: Unless prohibited by applicable law, we will charge yo ur account, as a Purchase, for any costs incurred by us associated with complying with state abandon property laws. Additional Account Fees an Charges: Please review the Required Federal Disclosure section of your card carrier for additional fees and ch rges that may apply to your account. Benefits You will be offered certain bei lest to the restriaions outlined f provided to you by MBNA Ameri reserves the right to adjust, add, services at any time and without fits which will be sub- the benefits brochure i. MBNA America r delete benefits and Refusal to Honor Your Card We are not liable for any refusal to honor your card or any Cash Advance or for any retention of your card by us, any other bank, or any seller or lessor of goods or services. Termination We may suspend or terminate our right to obtain credit at any time for any reason. Your obligations under this Agreement continue n after your right to obtain credit has been suspended or terminated. You must return all credit cards to us on request. Amendments We may amend this Agreement ak any time by adding, 5 SEP 16 2003 1209 PAGE. 06 F-16-NUS RR ie;ud rii aniw iatnnvciicni rnn au, ouc applicable notification requirement J laws of the State of Delaware. If an the opportunity to reject the chang change In the manner provided in may terminate your right to receive r to return all credit devices as a cor tion. The amended Agreement lih j or other higher charges or fer`fs}4vi unpaid balance, including the amendment became effective. We ? credit card with another card at a . U40U 1, VI/3., of federal law and the amendment gives you >, and if you reject the uch amendment. we credit and may ask you dition of your rejec- auding any higher rate I apply to the entire ice existing before the nay replace your time. We may at any time. and wit i assign your account, any sums this Agreement or our rights or I account or this Agreement to ai person or entity to whom we m shall be entitled to all of our rif under this Agreement, to the ex Your credit limit Is shown on yc eraly on each monthly statement. credit limit or limits from time to t you if we do. The total amount of any time must not be more than p also establish a separate credit lim we do, your outstanding Cash Adw exceed this Cash Advance limit. Request for Credit Ove Limits if you request credit in any form would result in either your total your Cash Advance balance, indu bons not yet posted to your aaou your credit limit or your Cash Adva have established one for you, lwhe ances before the request were mor credit limit), we may; (I J honor th manently raising your credit limit; and treat the amount which is mor 6 t notice to you, on your account, igations under your person or entity. The any such assignment and/or obligations assigned. card carrier and gen- e may change your ie, and we will ratify edit outstanding at r credit limit. We may for Cash Advances. If _e balance may not Your Credit if nding balance or d authorized transac- being more than ce credit limit, if we her or not such bal- than the respective request without per- ) honor the request than your credit limit SEP 16 2603 1209 PAW. 0? SEP-16-22 'flit: 1?:ua rn MM nRK%tntni SEP 16 2003 12:09 MA MU. Me 4?o U4JO r. uo/Io we may advise the person who has been refused. If we refuse I Advance or Balance Transfer. wi the person presenting the Chec Balance Transfer that credit has are insufficient funds to pay the Balance Transfer, or in any,othe it if we have previously horfd' cf F your credit limit, it does not me further overlimit requests. if we request, we may assess an over this Agreement. Unauthorized Use o Please notify us immediately o unauthorized use of your account Law nade the request that it honor a Check Cash may do so by advising Cash Advance or been refused. that there Check Cash Advance or quests for credit over in that we will honor decide to honor such a imit Fee as provided in Card the loss, theft, or possible it 1-800.7846701. This Agreement is made in 1 by the laws of the State of Del, its conflict of laws principles, r federal laws. If any part of this Agreement the rest remains effective. Our cising any of our rights under t) mean that we are unable to exe ware. It is governed re, without regard to by any applicable found to be invalid, lure or delay in exer- Agreement does not se those rights later. The Arbitration provisions ow apply to you unless you were given the opportunity o rejectthe Arbitration provisions and you did so rej them; in which case, you agree that any litigation b u ght by you against us regarding this account or this reement shall be brought in a court located in ih State of Delaware. Arbitration: Any claim or di pute ("Claim") by either you or us against the of er, or against the employees, agents or assigns f the other, arising from or relating in any way to his Agreement or any prior Agreement or your accou t (whether under a statute, in contras, tort or oth noise and whether for money damages, penalties or d daratory or equitable relief), including Claims regardi the applicability of this Arbitration, Section or the lidity of the entire 7 PAGE. 08 SEP-16-euu3 'rut lem en seas 1IMMOUtntrtl PHA nV. JUG 400 uqm r. vwia binding arbitration. The arbitration shall be condu ed by the National Arbitration Forum ('NAFi, under he Code of Procedure in effect at the time the Claim Is file o. Rules and forms of i the National Arbitration Forum be obtained and 1 Claims may be filed at any Natio al Arbitration Forum office, www.arb-forum cram, ' P. .'Bost Sl)191. Minneapolis, Minnesota 55?4fS4, t lephone 1.800 474.2371. If the NAF is unable or unwilling ad as arbitrator, we may substitute another nationall recognized, indepen dent arbitration organization that uses a similar code of procedure. At your written requ t, we will advance any arbitration filing fee, administrat ve and hearing fees which you are required to pay to ursue a Claim in arbi- n ation. The arbitrator will decid who will be ultimately responsible for paying those le . In no event will you be required to reimburse us for ny arbitration filing, administrative or hearing fees in as amount greater than what your coutt costs would hav been if the Claim had been resolved in a state court wi h jurisdiction. Any arbitration hearing at which you ppear wilt take place within the federal judicial district Iurt includes your billing address at the time the C im is filed. This arbitra- tion agreement-is made pursuant to a transaction involv- ing interstate:corrimerce, and sha 1 be governed by the Federal Arbitration Act, 9 US.C. § 1-16 ('FAA). Judgment upon any arbitration award may entered in any court having jurisdiction. The arbitrato shall follow existing substantive law to the extent con intent with the FM and applicable statutes of limitations nd shall honor any claims or.privilege recognized by I w. If any {carry requests, the arbitrator shall writ an opinion containing the reasons for the award, No Claim submitted to arbi'm and no Claim maybe brought as private'attomey general. You do as a class representative or panl F class of claimants with respect to Arbitration Section applies to ail I or that may arise irr the future. This Arbitration Section shall of your account with us as well a ment of the debt-in full by you, a SEP 16 2003 12:10 m is heard by a jury class action or as a >t have the right to act ate•as a member of a . ny Claim. This aims now in existence urvive the termination any voluntary pay- y bankruptcy by you PAW.09 StP_'V_euuo r uc tc, r u ru om co iumnuuuau .1, 1. 1 nA 11V, J,, ?(Iu U'Ju I, Jul,, i i SEP 16 2063 12:1B or sale of the debt by us. For the purposes of this Arbitration on, "we" and -us` means MBNA America Bank. NA, its rent, sub- sidiaries. affiliates. licensees, predecessors successors. assigns, and any purchaser of your accoun , and all of their officers, directors, employees, agents and ssigns or any and all of them. Additionally, 'we" or -us shall mean any third parry providing benefits, servl&. ' products in connection with the account (including ut not limited to credit bureaus, merchants that accept any credit device issued under the account, reward or enrollment services, credit insurance companies, de collectors -and all of their officers, directors, empio es and agents) if, and only if, such a third party Is nam by you as a -co-defendant in any Claim you assert a inst us. Also. for the purposes of this Arbitration Sect on, 'you' or yours` shall mean any person or entity pproved by us to use the Account, including but not It ited to all per- sons or entities contractually obligated n the Account and all authorized users of the account. If any part of this Arbitration Section is found to be Invalid or unenforceable under any law r statute consis- tent with the FAA, the remainder of this Arbitration Section shall be enforceable without re and to such invalidity or unenforceability. THE RESULT OF THIS ARB)TRATIO AGREEMENT IS THAT, EXCEPT AS PROVIDED ABOV , CLAIMS CAW NOT BE LITIGATED )N COURT. INCLU INC SOME CLAIMS THAT COULD HAVE BEEN ED BEFORE A JURY. AS CLASS ACTIONS OR AS PRN TE ATTORNEY GENERAL ACTIONS. Platinum Plus Coverage -C it Insurance Benefits, Limita ions, Costs & Exclusions Platinum Pju r Covemee pays your mi imum monthly payment up to your balance on the da of loss fnot to exceed S) 5,1700), until you return to wo •' if you are involuntarily unemployed, IQta& disabl , or if you or your spouse takes covered family leave. Platinum Plus Coverage also pays your insured outsta ding balance up to the least of your outstanding balan , your credit limit, or $15,000 if you die. 9 SEP-16-2D03 'M 12:IU PI1 SALES tuiNRGEMNI m Nu, due qO ug3u r. It/Id the primary caronotaer or a rn are not eligible), under age 66 FL, GA, Ml. MO&OK;72inI'these same ages (except family unemployment unless fn TX). will be mailed explaining your c MN, unemployment coverage is your certificate effective d* F ly leave benefits, you must be gat least 30 hrs/wk (not self empl contractor) for 90 consecutive d (CO - before application date), (TX - before coverage effective d Employees of professional co Covereees & Benefits: Plat your death; involuntary unemp general strike, unionized labor disability due to sickness or inj perform the material & substan any lob after the first J 8 mos. in mos. in PA); your or your spouse absence from employment due t newly adopted child or an incap member (must be spouse, child, AK), mandatory recall to active n (except in AK), or residence in a ter area. Loss (not death) must days before benefits begin. In K labor disputes & lockouts, you n 7 consecutive weeks & qualify fo benefits before benefits begin. each day of loss over 30 days for I PA, and disability In CA, CT, NY, I cancel this coverage at any time., 30 days of coverage, all premium Exclusions- Life: suicide in t coverage (not MD & MO). Jnvol retirement, resignation, volunta fob loss due to willful or criminal strikes in 1L, military discharge in unemployment In TX. Disability: childbirth snot CA, MA & NV), int injuries (not MD) or a pre-existin )0 a pecan[, autnonzea users in AZ. NV & VA; 71 in M . Your coverage ends at 1 ave in AZ, FL & SD & hen enrolled, certificates verage & effective date. In festive 61 days from r unemployment or fami- Jnfully employed working yed or an independent before the date of loss A - on the date of loss), to for unemployment). adons may be eligible. um Plus Coverage covers: ent due to job loss, ispute or lockout; total ry if you are unable to lal duties of your job Jor, Hl, NJ, TN & WI; 12 s unpaid leave of . care of your newbom or citated immediate family stepchild or parent in ,ilitary duty, jury duty ederally declared disas- continue at least 30 Y. for strikes, unionized ust be unemployed for state unemployment daily benefit is paid for unemployment in NY & Ai, PA & SC. You may Jf canceled within first will be refunded. to first 6 months of ntary Unemployment: forfeiture of income or misconduct, disability, NY, normal seasonal normal pregnancy or medical condition SEP 16 2003 1210 PAM. II 51 Y-I Vevua iut lc/ iu rll anLLO IuvulvL luu 111(1 IIV- JVL Z VYJV A. lb lJ benefits are not paid if ) unemployment benefits This is only a brief de ages vary, by state. Plea full explanation of cove are eligible for or receiving are disabled. ption of coverage, and cover- efer to your certificates for a SOP Is 2003 12:10 Costs apply to Life 9. D & Family Leave'fF): AU4'i CA 89.94: CO 52.35(; CT 4 89c; GA 884; HI 89.91 r It F 20c); IL 80c; IN 96c: IA 200 KS 85.41; KY 97.4; MI 85.7(; MN 30.65(; MS 95.84; NV 95.34: NH 954; 8.8c. D 26.84. U 16.90); N( 92.4; OR 64.74; PA 38.14; 96.89(; TN 92.54; 7X 33.74 91.88(; VT 28.44 (L 5.994, D 8.9c. U 494, F 200); WA I 5.7c, D 8.9c, U 594, F 200; Availability: This Involuntary Une mph Family Leave is not NM, NY, PA, or TX . Unemployment: America NY(3/931, AS LOI 7% (6192 IP; Standard GuarantyiSG Disability: Union Security Life (7X only)/L-I-Z (8/92)( Life onlyyNYLM0013: and Disability only)/W--S-A Far Secutity/FLP (4/971. FLP-F1 in NC, FLP-OK (4/97) in Of (AZ)(7/96) in AZ, FLIP (4/9 in KS, FLIP-WY (4/97) In (4/97) in NH; Union Secud Soliciting agents for Miss! M. Gordon and Pamela Cu This product is not an in FDIC insured, Is not guaran NA, and is not a condition bility (D), Unemployment (UI : AK 78c; AZ 99c; AR 97,54; .894; DE 96.97(; DC 95.3(; FL 5.2c (L 8.6c, D 12.64. U 54c, 6c (L 7.2c. D 14.44, U 54c, F 89.74: MD 70.54(: MA 18.4(; 5.2c; MO 61.1c; MT 93.9c; NE I) 97c; NM 58.94: NY 52.54 (L 74.3( ND 94.14; OH 99c; OK PR 99t: R1 93.15c; SC 80c: SD (L 5.7c. D 12c, U 1641: UT ) 6.41 c, F 16c): VA W (L 6.1c. 4c; WV 95.24; W) 93.6c (L WY 95.54. ge is not available in ME. is not available in MA or VT. le in AL, CT, MA. MD, MN, e1291)t: Involuntary Securi- 01(5/85). LOI LOIC-)P-KS (2/96). and LOIG .01(5/85) (NH only). Life & Life(L-14; Standard Guaranty .53RA); First Fortis Life (NY lmerican Security (NY fly Leave: -American 02197) in FL, FLP-NC (3/98) FLP-VA (1198) in VA, FL-IP I in1L & IN, FL-IRKS (12197 f; Standard Guaranty/FLP Llfe/FLP-VT (4/97) in VT. ipp! and Florida are Charles Is respectively. red deposit account, is not ed by MBNA America Bank, f obtaining credit. PRLE.12 SEP-16-zuUJ tut: Iru rn bflUb (IrlnevMVII rtia nv, svc Voo vvoo r. ti/ii coverage pays 5% of the balan on your date of disability up to $750. In NY, coverage pays the minimum payment due on your date of loss. "fie number of monthly ber efit payments will not exceed 9 for family leave: 12 for unemployment in AL. AK. CT. IL. Mi. MN, MO, NM. NC. NY, PA SC & TX: 12 for disability ex0o In CA, MI, IN, KS. 4441. NY. PA, TN. TX b W). NY, -N) & TX Residents On : To purchase coverages separately, write to Assurant Group, P.O. Box 50355, Atlanta, GA 30302. Applications will be sent to you. i MBNA America Bank NA., is th exclusive'issuer And administrator of this and other ` latinunr Plus cfedit card 1 accounts 1 MBNAAmerica® is a federally re gistered service mark of MBNA America Bank NA. O 2000 MBNA America Bank, N NEX790 (Revised 4/2000) DISC-58 ' 4/1/00 MBNAULOI fMBNA-L/D/U capped LOVFL) 12. PPGE.13 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA C.S. 4904 relating to unswom falsifications to authorities, that he/she is Personal Banking Officer of (TITLE) he/she is duly authorized to make this verification, and that the facts Complaint are true and correct to the best of his/her knowledge, Hobbis plaintiff herein, that forth in the foregoing and belief. WWR# 04606771 r -Zi W p ? N 4C ult (R ('L.J 1 5 Gy UV) 0 _ 1, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MBNA AMERICA BANK, NA Plaintiff vs. ALEKSANDR KOREBA Defendant No. 06-3220 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Benjamin R. Bibler PA I.D. #93598 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04944202 Judgment Amount $ 20,213.63 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MBNA AMERICA BANK, NA Plaintiff vs. Civil Action No. 06-3220 CIVIL TERM ALEKSANDR KOREBA Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, ALEKSANDR KOREBA above named, in the default of an Answer, in the amount of $20,213.63 computed as follows: Amount claimed in Complaint $20,213.63 Interest from date of judgment at the legal interest rate of 6% per annum TOTAL $20,213.63 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. & REIS CO., L.P.A. By: ?_.. Ben' min R. Bibler P I.D.#93598 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04944202 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`s Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 208 SENATE AVE APT #611, ENOLA,PA 17025 MBNA IN THE CO T OF COMMON PLEAS CUMBERLAND COUNTY, CIVIL DIVISION PENNSYLVANIA Plaintiff Case # ALEKSANDR KOREBA Defendant(s) IMPORTANT NOTICE TO: ALEKSANDR KOREBA 208 SENATE AVE APT #611 ENOLA,PA 17025 Date of Notice: WWR#: 04944202 ?i YOU ARE I DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PER ONALLY 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 NONCE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL i SERVIggS,TO EL GIBLE PERSONS AT A REDUCED FEE OR NO FEE,. LAWYER REFERP-" SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166, s BY : ?SI JAMES J"MBRODT, ESQUIRE'. PA I.D. #42524 WELTMAN, WEINBERG & REIS.CO., L.P.A. 2718 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MBNA AMERICA BANK, NA Plaintiff vs. ALEKSANDR KOREBA Case no: 06-3220 CIVIL TERM NON-MILITARY AFFIDAVIT Defendant 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, ALEKSANDR KOREBA 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, ALEKSANDR KOREBA is not in the military service. Further Affiant sayeth naught. SWORN T AND SUBSC IB Din my presence this day of. CddM?N?'tEAl??p ?NNgYLVANIA Wayne A Jaffee, NoWY ?? NOT *Y PUBLI glydpNtfdedSANa ? ??? quodeeon d Noterlss tMmDer, Peamy?w"? 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 JUL-18-2006 09:19:16 C Last Name First/Middle Begin Date Active Duty Status Service/Agency KOREBA ALEKSANDR 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: http //www.defensOink.mil/faa/ois/PC09SLDR htm1 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 7/18/2006 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: MNWHYUUKJC https;//www.dmdc.osd.mil/scra/owaJscra.prc_Select 7/18/2006 t? d G -(4. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MBNA AMERICA BANK, NA Plaintiff VS. Civil Action No. 06-3220 CIVIL TERM ALEKSANDR KOREBA Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order r J gment was entered against you on% JfI ZOOG (xx) Assumpsit Judgment in the amount of $20,213.63 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 Sy: PRO NOTAR ) ALEKSANDR KOREBA 208 SENATE AVE APT #611 ENOLA,PA 17025 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7" Avenue, Pittsburgh, PA 15214 1-888-434-0085 SHERIFF'S RETURN - REGULAR CASE NO: 2006-03220 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MBNA AMERICA BANK NA VS KOREBA ALEKSANDR MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon KOREBA ALEKSANDR the DEFENDANT , at 1735:00 HOURS, on the 7th day of June , 2006 at 208 SENATE AVENUE APT 611 ENOLA, PA 17025 by handing to ALEKSANDR KOREBA 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: So Answers: Docketing 18.00 Service 12.32 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 40.32t/ 06/08/2006 WELTMAN WEINBERG REIS Sworn and Subscibed to By: before me this day Deput Sheriff of A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MBNA Plaintiff vs. ALEKSANDR KOREBA Defendant No. 06-3220 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION (LEVY 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. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04944202 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MBNA Plaintiff vs. Civil Action No. 06-3220 CIVIL TERM ALEKSANDR KOREBA Defendant 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 ALEKSANDR KOREBA, 208 SENATE AVE, APT #611, CAMP HILL, PA 17011, Defendant 3. Judgment Amount $ 20213.63 Interest $ 2548.57 Costs $ SUBTOTAL: $ 22762.20 Costs (to be added by Prothonotary): $ WELTMAN, WEINBERG & REIS CO., L.P.A. By: 422'z- -?? William T. Molczan, Esquire PA I. D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04944202 PLEASE LEVY ON ANY/ALL OF DEFENDANT'S PROPERTY AT GIVEN ADDRESS. W W f _ W M r r-; m to rr U1 O f i COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND MBNA Plaintiff No. 06-3220 CIVIL TERM vs. ALEKSANDR KOREBA Defendant WRIT OF EXECUTION NOTICE This paper is a "Writ of Execution". It has been issued because there is a judgment against you. It may cause your property to be held or taken to pay the judgment. You may have legal rights to prevent your property from being taken. A lawyer can advise you more specifically of these rights. If you wish to exercise your rights, you must act promptly. The law provides that certain property cannot be taken and sold by the Sheriff to satisfy your debts. SUCH PROPERTY IS SAID TO BE EXEMPT. No matter what you may owe, there is a DEBTOR'S EXEMPTION established by law. This means that no matter what happens, the Sheriff must give you from the sale at least $300.00 in cash or property. There are also other exemptions which may be applicable to you. Listed below is a summary of some of the major exemptions. You may have other exemptions or other rights. If you have an exemption, you should do the following promptly: (1) Complete the claim form on the opposite side and demand a prompt hearing. (2) Deliver the form or mail it to the Sheriffs Office at the address noted. You should come to court when and where you are told to appear ready to explain your exemption. IF YOU DO NOT COME TO COURT AND PROVE YOUR EXEMPTION, YOU MAY LOSE SOME OF YOUR PROPERTY. 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. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 TELEPHONE NO.: (717) 249-3166 MAJOR EXEMPTIONS UNDER PENNSYLVANIA AND FEDERAL LAW 1. $300.00 exemptions set by law. 2. All wearing apparel used by yourself and all family members. 3. Bibles, school books, sewing machines, uniforms & equipment. 4. Tools of your trade such as carpenter's tools. 5. Most wages & unemployment benefits. 6. Social Security benefits, certain retirement funds and accounts. 7. Certain veteran & armed forces benefits. 8. Certain insurance proceeds. 9. Such other exemptions as may be provided by law. CLAIM FOR EXEMPTION TO THE SHERIFF: I, the above-named defendant, claim exemption of property from levy or attachment: (1) FROM MY PERSONAL PROPERTY IN MY POSSESSION WHICH HAS BEEN LEVIED UPON, (a) I desire that my statutory $300.00 exemption be: (__) (1) set aside in kind (specify property, to be set aside in kind: (_) (2) paid in cash following the sale of the property levied upon; or (b) I claim the following exemption: (specify property and basis of exemption): (2) FROM MY PROPERTY WHICH IS IN THE POSSESSION OF A THIRD PARTY, I CLAIM THE FOLLOWING EXEMPTIONS: (a) my $300.00 statutory exemption: (_) in cash in kind (specify property): (b) (c) Social Security benefits on deposit in the amount of $ Other (specify amount & basis for exemption): I request a prompt court hearing to determine the exemption. Notice of hearing should be given me at the following: ADDRESS: TELEPHONE NUMBER: I verify that the statements made in this Claim for Exemption are true and correct. I understand that false statements herein are made subject to the penalties of 18 PA. C.S. § 4904 relating to unworn falsification to authorities: Date: Defendant: THIS CLAIM TO BE FILED WITH: Office of the Sheriff of Cumberland County One Courthouse Square, Cumberland County Courthouse Carlisle, Pennsylvania 17013 Telephone Number: (717) 240-6390 Note: Under paragraphs (1) and (2) of the Writ, a description of specific property to be levied upon or attached may be set forth in the Writ or included in a separate direction to the Sheriff. Under paragraph (2) of the writ, if attachment of a named garnishee is desired, his name should be set forth in the space provided. Under paragraph (3) of the writ, the Sheriff may, as under prior practice, add as a garnishee any person not named in this writ who may be found in possession of property of the defendant. See Rule 3111(a). For limitations on the power to attach tangible personal property, see Rule 3108(a) (b). Each court shall, by local rule, designate the officer, organization or person to be named in the notice. WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) N006-3220 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MBNA Plaintiff (s) From ALEKSANDR KOREBA 208 SENATE AVE, APT #611 CAMP HILL, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell PLEASE LEVY ON ANY/ALL OF DEFENDANT'S PROPERTY AT GIVEN ADDRESS.. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of 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 $20,213.63 Interest $2,548.57 Atty's Comm % Atty Paid $13132 Plaintiff Paid Date: SEPTEMBER 15, 2008 L.L.$0.50 Due Prothy $2.00 Other Costs e'11-4 ";' ?J'. A RCurKR. Long, o ary (Seal) By: Deputy REQUESTING PARTY: Name WILLIAM T MOLCZAN ESQUIRE Address: 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: (412) 434-7955 Supreme Court ID No. 47437 R. Thomas Kline, Sheriff, who being duly sworn according to law, states this ?t Writ is returned ABANDONED, no action taken in six months. Sheriff's Costs: Advance Costs: 150.00 Sheriff's Costs: 77.11 Docketing 18.00 72.99 Poundage 1.51 Advertising Refunded on 04/20/09 Law Library .50 Prothonotary 2.00 Milage 15.00 Misc. Surcharge 20.00 Levy 20.00 Post Pone Sale Certified Mail Postage Garnishee So Answers, 77.11 ? y????o9 R. Thomas Kline, Sheriff By aron R. Lantz X17 0 Vi u N a G 4 / SY i ?. :z a yns s? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) N006-3220 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MBNA Plaintiff (s) From ALEKSANDR KOREBA 208 SENATE AVE, APT #611 CAMP HILL, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell PLEASE LEVY ON ANY/ALL OF DEFENDANT'S PROPERTY AT GIVEN ADDRESS.. (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of 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 $20,213.63 Interest $2,548.57 Atty's Comm % Atty Paid $131.32 Plaintiff Paid Date: SEPTEMBER 15, 2008 L.L.$0.50 Due Prothy $2.00 Other Costs .19 ?1'2L2" R. Long, P notary C s (Seal) By: Deputy REQUESTING PARTY: Name WILLIAM T MOLCZAN ESQUIRE Address: 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: (412) 434-7955 Supreme Court ID No. 47437 r1a c:n IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MBNA Plaintiff vs. ALEXSANDR KOREBA Defendant No. 06-3220-CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION (LEVY 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. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04944202 w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION MBNA Plaintiff vs. Civil Action No. 06-3220-CIVIL TERM ALEXSANDR KOREBA Defendant 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 ALEKSANDR KOREBA, Defendant aol3 Senate. Aue/Apt*btl 3. Judgment Amount Iy0!! $ 20213.63 brnp gill, PA Less payments of $ 59.68 Interest $ 3312.81 Costs $ SUBTOTAL: $ 23466.76 Costs (to be added by Prothonotary): $ WELTMAN, WEINBERG & REIS CO., L.P.A. a By: L/d William T. Molczan, quire PA I. D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04944202 0 RLED-OF ICE OF THE I TNC)NOTARY 209MAY -7 PM 12: 37 wij;wy PENNSYLVANIA 40.w po A` -N 40. Sa COF 117-11 of 66.50 q • Oo ?? aq.OO " ug. 93 -Po Y 4 a.oo 6XI lA UY g8 IW W* A q 4905 'A U,)fi+ 0? 4 %11 ? WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 06-3220 Civil COUNTY OF CUMBERLAND) CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MBNA, Plaintiff (s) From ALEXSANDR KOREBA, 208 Senate Ave, Apt #611, Camp Hill, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell any and all property . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of 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 $20,153.95 Interest -- $3,312.81 Atty's Comm % Arty Paid $229.93 Plaintiff Paid Date: 5/07/09 L.L. Due Prothy $2.00 Other Costs I d"e?4L - s R. Long, on tary(Seal) By: Deputy REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 47437 R. THOMAS KLINE Sheriff EDWARD L.SCHORPP Solicitor o0ty of ?CuntbPr?? ?/It.L 4.! i I t , OFFICE OF THE SHERIFF ; One Courthouse Square, Room 303 Carlisle, Pennsylvania 17013 9 A U G 12 tia'I 3. 30 RONNY R. ANDERSON Chief Deputy August 3, 2009 MBNA ? JODY S. SMITH Real Estate Sergeant vs Alexsander Korebal Writ No. 2006-3220 Civil Term Property Claim Determination To Whom It May Concern: Reference is made to Property Claim dated July 23, 2009, entered by Kristen Leach, on behalf of Susquehanna View Apartments, Writ of Execution No. 2006-3220 Civil Term, MBNA vs Alexsander Koreba. R. Thomas Kline, Sheriff, has determined that the claimant, Kristen Leach, on behalf of Susquehanna View Apartments, in the above mentioned property claim, is the owner of the property set forth in the claim. So Ans r ' V, ooppww - - - - 0 t ??z R. Thomas Kline, Sheriff By cc William T. Molczan, Atty for Plaintiff Alexsander Koreba, Defendant Kristen Leach, Claimant on behalf of Susquehanna View Apartments .1 11 NOTICE OF PROPERTY CLAIM MBNA In the Court of Common Pleas Cumberland County, Pennsylvania VS Alexsander Koreba No. 2006-3220 Civil Term Writ of Execution TO THE DEFENDANT AND ALL OTHER PARTIES IN INTEREST: You are hereby notified that a property claim, a copy of which is attached hereto has been filed by Kristen Leach claiming property listed therein. Unless an appraisal of the property is requested within (10) days from the date of this notice, the Sheriff without making an appraisal will accept the value of the property set forth in the claim. Date 07-23-09 Shenff of Cumberland ounty By Cc ",?A A?W William T. Molczan, Atty for Pltff Alexsander Koreba, Defendant Kristen Leach, Claimant on behalf of Susquehanna View Apartments PROPERTY CLAIM TO THE SHERIFF OF CUMBERLAND COUNTY, PENNSYLVANIA In the Court of Common Pleas of Cumberland County, Pennsylvania Writ No. The property listed below and levied upon in this case is not the property of the defendant, but is the property of the undersigned. A list of the claimed property and the values thereof are: LIST OF PROPERTY VALUE hmwy) U?ar' ?' ?a - ??\ - ?06? ? THE CLAMANT OBTAINED TITLE TO THE PROPERTY AS FOLLOWS: Date State. of Pennsyl . County of Cumb land above list in the roperty claim 06 correct and true. Sworn and subscribed to before me This J.q?4dav of li° OTARIAL SEAL KA A. ZEIGLER, NOTARY PUBLIC TORO OF CARLISLE, CUMBERLAND COUNT MY COMNIISSIDN EXPIRES JUNE 11, 2013 en-fiery Lfac t-? being d y sworn according to la ,deposes and says that the Claiimint ? CaW\1?) \\A\\, `?? \"lC)\\ Jul. 23. 2009 10:00AM No. 4262 P. 1 AIMCO Apartment Irnesfinem and Management Company July 23, 2009 Thomas Kline Sheriff, Cumberland County 1 Courthouse Square, Room 303 Carlisle, PA 17013 Dear Sheriff Kline: Please be advised that Kristen Leach, Community Manager of Susquehanna View Apartments in Camp Hill, PA is authorized to file claim on behalf of said apartment complex and AIMCO, the Property Management Company of Susquehanna View Apartments, Kristen Leach, CM will be filing for: 1 • Hotpoint Refrigerator 1 - Brown Rangemaster Electric Stove These Items were in the unit of Alexsandr Koreba - 208 Senate Avenue - Apartment 611 -Camp Hill, PA 17011 AIMCO understands that these items are slated to be sold on August 13, 2009 at 3 pm. Please allow Kristen Leach, on behalf of AIMCO, to file for purchase of these items. Sincerely, +1'&V Karyn Marasco, Senior Vice President AIMCO Operations Northeast 301 Oxford Valley Road Suite 1801, 2"d Floor Yardley, PA 10067 216-493.4041 301 OXFORD VALLEY ROAD - SurrB 1801A, 2ND FLOOR - YARDLEY, PA 19067 TaLwHONB (215).493-4041 - FAcsimim (215) 493-7314 " w Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor MBNA vs. Alexsandr Koreba SHERIFF'S OFFICE OF CUMBERLAND COUNTY ?gxxYxtr pt ?uit?brrf??? ¢FFjCE OF 1-F '?iRIFF F1LED-07r-c 3' s?^, c,TARI' I or- THE 21I1, M; R 21.4 PH 2* 33 1 Case Number 2006-3220 SHERIFF'S RETURN OF SERVICE 05/13/2009 07:45 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on May 13, 2009 at 1945 hours, he served a true copy of the within writ of execution, upon the defendant, to wit: Alexsandr Koreba, by making known unto Alexsandr Koreba, at 208 Senate Avenue, Apt. 611, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. Upon serving the writ of execution, a levy was completed. Postcard mailed to attorney and letter mailed to defendant on 05-18-09. 07/09/2009 07:00 PM -Sale bill posted on 07-09-09 at 1900 hours by Deputy Harrison. Sale date set for thursday, 08-13-09 at 1500 hours. Copy of sale bill mailed to Attorney Molczan. 07/23/2009 On Thursday, July 23, 2009, at 1256 hours, a property claim was filed by Kristen Leach, who is the Community Manager of Susquehanna View Apartments, where the defendant lives. Moyer claimed several items on behalf of Susquehanna View Apartments that were furnished to the defendant for the defendant to use. All parties notified by mail this date. 08/03/2009 Reference is made to Property Claim dated July 23, 2009, entered by Kristen Leach, Claimant on behalf o Susquehanna View Apartments, Writ of Execution No. 2006-3220 Civil Term, MBNA vs Alexsander Koreba. R. Thomas Kline, Sheriff, has determined that the claimant, Kristen Leach, on behalf of Susquehanna View Apartments, in the above mentioned property claim, is the owner of the property set forth in the claim. 03/24/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $ 117. 85 March 24, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF j -CO rd - co 1,64 7y Ic7 Goun'ySufte Jhe;ifl, Te!easoft. Inc. t • - WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-3220 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due MBNA, Plaintiff (s) From ALEXSANDR KOREBA, 208 Senate Ave, Apt #611, Camp Hill, PA 17011 (1) You are directed to levy upon the property of the defendant (s)and to sell any and all property . (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of 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 $20,153.95 Interest -- $3,312.81 Atty's Comm % Atty Paid $229.93 Plaintiff Paid L.L. Due Prothy $2.00 Other Costs Date: 5/07/09 (Seal) Curtis R. Long, P onota By: Deputy REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 47437