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HomeMy WebLinkAbout06-3630 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. SHIRLEY A ALEXANDER Defendant No. O` - .34.3 D inoi(, 1 euw-? COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C. WARMBRODT, ESQUIRE PA I.D.#42524 Weltman, Weinberg & Reis Co., L.P.A. 2718=Koppers Bldg. 436'Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 WWR#05215567 r_. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. SHIRLEY A ALEXANDER Defendant COMPLAINT IN CIVIL ACTION 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 LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 IN THE COURT OF COMMON PLEAS'CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. Q(o - 94G,iO SHIRLEY A ALEXANDER Defendant COMPLAINT AND NOW COMES, Plaintiff, by and through its counsel, WELTMAN, WEINBERG & REIS, CO., LPA., and hereby files this Complaint against Defendant, SHIRLEY A ALEXANDER, and, in support thereof, Plaintiff avers as follows 1. The Plaintiff is a corporation with its principal place of business located at P.O. Box 85147, Richmond, VA 23285. 2. Plaintiff is the owner of this account, which is the subject matter of this action. 3. Defendant is an adult individual residing at 67 SPRING RD CARLISLE,PA 17013 . 4. Defendant requested the account and made use of said account and has currently a balance due and owing to Plaintiff, as of JUNE 22, 2006, in the amount of $2,071.34 . 5. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, SHIRLEY A ALEXANDER, individually, in the amount of $2,071.34 with finance charges thereon at the rate of 20.65% per annum from JUNE 22, 2006, plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. JAM WARMBRODT, ESQUIRE PA .D. 2524 W Itm , Weinberg & Reis Co., L.P.A. 18 oppers Bldg. 3Avenue urgh, PA 15219 434-7955 WWR#: 05215567 V w VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA. C.S. 4904 relating to unworn falsifications to authorities, that he/she is a'rQ, It J-h to ^ ?1 \ - (NAME) RQ, /Y?` of GG? (A Sh ?^e, ? 1 / , plaintiff herein, that I- (TITLE) (COMPANY) he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief. (SIGNATURE) WWR# 0S-2L F? t/1 • t? ..+.. ? ? ? C ? N 6' (,? -? '? r? n C_' .?.a '?'t r -?, .,-' ? ,r; c, :: ? ??-? r ? ?? `"+, _ 1' r7 :? ._ r.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL. DIVISION CAPITAL, ONE BANK Plaintiff Vs. SHIRLEY A ALEXANDER Defendant No. 06-3630 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt Paid# 42524 Weltntan. Weinberg & Reis Co. 2718 Koppers Bldg 436 Seventh Avenue Pittsburgh. PA 15219 (412)414-7955 WWR705215567 Judgment Amount S 2127.59 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL. DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 06-3630 CIVIL TERM SHIRLEY A ALEXANDER Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, SHIRLEY A ALEXANDER above named, in the default of an Answer, in the amount of $2127.59 computed as follows: Amount claimed in Complaint $2071.34 Interest from 06/22/06 at the legal interest rate of 20.65% per annum $56.25 TOTAL $2127.59 1 hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, W EINBERG & REIS CO., L.P.A. By. I r v V _ James C. rmbrodt Pai& 5 4 Weltm , einberg & Reis Co. 2718 op ers Bldg 436 ev nth Avenue Pitt glt, PA 15219 (41 4-7955 W 405215567 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7" Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 67 SPRING RD CARLISLE,PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff SHIRLEY A ALEXANDER Defendant(s) IMPORTANT NOTICE TO: SHIRLEY A ALEXANDER 67 SPRING RD CARLISLE,PA 17013 ?r Date of Notice: Ins/?! WWR#: 05215567 Case # 4)Cri' f IVr?L ?? YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 C BY: V V /v - v JAME$ WARMBRODT, ESQUIRE PA I`. #42524 WELT WEINBERG & REIS CO., L.P.A. 2718 OPPERS BLDG, 436 7TH AVE. PIT BURGH, PA 15219 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. SHIRLEY A ALEXANDER Case no: 06-3630 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, SHIRLEY A ALEXANDER 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. SHIRLEY A ALEXANDER is not in the military service. Further Affiant sayeth naught. AFF TO AND SVJB$CRIBED in my presence this (6 day of -A BYI.VATIIA Y PU W110011111 A.Jon@%WayPUdb Clly Of Pft1h9Q b A1100 iry County My Canmkelon EmM June 211, 2010 Member, Pennsylvania Assodation of Notaries 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 ;p. Page I of 2 AUG-09-2006 06:27:53 Last Name First/Middle Begin Date Active Duty Status Service/Agency ALEXANDER SHIRLEY A 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. Mary M. Snavely-Dixon, 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. #167;#167; 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. Sue: http:/,Iwww.defense]ink.niil/faq/pis/11C09SLDR.hiniI WARNING: This certificate was provided based on a name and Social Security number (SSN) provided htips://www.dmdc.osd.mil/scra/owa/scra,prc_Select 8/9/2006 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 11TPUJLLWOSDC https://w-ww.dmdc.osd.mil/scra/owa/scra.prc_Select 8/9/2006 _ N Ci P n C c Jr. • r ' ; - c co IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. 06-3630 CIVIL TERM SHIRLEY A ALEXANDER Defendant NOTICE OF JUDOMEN'f OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order Judgment was entered a ainst you on 1 A00(0 (xx) Assumpsit Judgment in the amount of $2127.59 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 ( 1 Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( I Arbitration Award Prothonotary By... PRO ONOTARY EP Y) SHIRLEY A ALEXANDER 67 SPRING RD CARLISLE,PA 17013 Plaintiffs address is: c/o Wellman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7" Avenue, Pittsburgh, PA 15219 1-888-434-0085 SHERIFF'S RETURN - REGULAR CASE NO: 2006-03630 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS ALEXANDER SHIRLEY A SHARON LANTZ Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon ALEXANDER SHIRLEY A the DEFENDANT , at 1509:00 HOURS, on the 30th day of June 2006 at 67 SPRING ROAD CARLISLE, PA 17013 by handing to SHIRLEY ALEXANDER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 4.40 Affidavit .0011100, Surcharge 10.00 R. Thomas Kline nn 32.40,/ 07/05/2006 171)41,4 WELTMAN WEINBERG REIS 7 Sworn and Subscibed to By: before me this day Deputy heriff of A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. SHIRLEY A ALEXANDER Defendant No. 06-3630 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#5215567 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. SHIRLEY A ALEXANDER , &7 Spr-1n P.cI Defendant CowhS6' A 17013 Civil Action No. 06-3630 CIVIL TERM 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 SHIRLEY A ALEXANDER, Defendant - levee{ m Persor-"FX*Peil 3. Judgment Amount $ 2127.59 Interest $ 244.82 Costs $ SUBTOTAL: $ 2372.41 Costs (to be added by Prothonotary): $ WELTMAN, WEINBERG & REIS CO., L.P.A By: 1.64ZL-f William T. Molcz 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#5215567 W .?• 0 0 ,? 0 b z = d ?b -c r t C.r L3E c7n ?T z CD M COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND CAPITAL ONE BANK Plaintiff No. 06-3630 CIVIL TERM VS. SHIRLEY A ALEXANDER 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 C_) 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 unsworn 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) COUNTY OF CUMBERLAND) NO 06-3630 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CAPITAL ONE BANK, Plaintiff (s) From SHIRLEY A. ALEXANDER, 67 Spring Road, Carlisle, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell personal 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 $2127.59 Interest -- $244.82 Atty's Comm % Atty Paid $123.40 Plaintiff Paid Date: 8/04/08 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs S • - ki. 1111 R. Long, Prothonotary By: t. Deputy REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., LPA 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 Writ is returned ABANDONED, no action taken in six months. Sheriffs Costs: Docketing Poundage Advertising Law Library Prothonotary Mileage Surcharge Levy Postpone Sale Certified Mail Postage Garnishee - J S rp- "a LIA CT a CD N ? zujj?c 18.00 1.32 .50 2.00 5.00 20.00 20.00 .44 67.26 00 :b V q- ??+ BGOc Advance Costs: 150.00 Sheriff's Costs: 67.26 82.74 Refunded on 05/18/09 So Answers, R. r;' Kline, Sherj I ?Q G 55 ? o 0 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-3630 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CAPITAL ONE BANK, Plaintiff (s) From SHIRLEY A. ALEXANDER, 67 Spring Road, Carlisle, PA 17013 (1) You are directed to levy upon the property of the defendant (s)and to sell personal 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 $2127.59 Interest -- $244.82 Atty's Comm % Atty Paid $123.40 Plaintiff Paid Date: 8/04/08 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs ks . Long, Prothonotary By: a- V. Deputy REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., LPA 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412434-7955 Supreme Court ID No. 47437