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HomeMy WebLinkAbout06-3808 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. NAOMI M LUTZ Defendant No. 0`^,.3Pc1-*4P GWIL ?Pn 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 Building 4is'86venth Avenue - P+YNsburgh, PA 15219 (412) 434-7955 WWR#05214734 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. Civil Action No. NAOMI M LUTZ 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 DtVl-SI`ON CAPITAL ONE BANK Plaintiff t vs. Civil Action No. Qt. -3jbr> ?lUf1+1 NAOMI M LUTZ Defendant COMPLAINT AND NOW COMES, Plaintiff, by and through its counsel, WELTMAN, WEINBERG & REIS, CO., LPA., and hereby files this Complaint against Defendant, NAOMI M LUTZ, 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 120 E DAUPHIN ST ENOLA,PA 17025 4. Defendant requested the account a'rid trade use of said account and has currently a balance due and owing to Plaintiff, as of JUNE 26, 2006, in the amount of $2,535.71. 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, NAOMI M LUTZ, individually, in"the amount of $2,535.71 with finance charges thereon at the rate of 20.65% per annum from JUNE 26, 2006, plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS,00., L.P.A. Warmbrodt, PA I 42524 W TM N, WEINBERG & REIS CO., L.P.A. 2 18 K ppers Building 6 S venth Avenue itts , rgh, PA 15219 ( J'434-7955 05214734 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 JCLC0- dtubt-) (NAME) R of plaintiff herein, that ` (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) W WR# • ? rJ q,. r-, )?T1 r? :.t 0 SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-03808 P COMMONTLdEALT.H OF PENNSYLVANIA COUNTY OF CUMBERLAND CAPITAL ONE BANK VS LUTZ NAOMI M R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT LUTZ NAOMI M but was unable to locate Her in his bailiwick. He therefore returns the /" nMTAT T TTT'T f_ TTnrrTOV NOT FOUND , as to the within named DEFENDANT LUTZ NAOMI M 120 E DAUPHIN STREET ENOLA, PA 17025 DEFENDANT NOT FOUND AT EITHER 120 E DAUPHIN ST OR 4420 GETTYSBURG RD APT 7 CAMP HILL. Sheriff's Costs: So answer " Docketing 18.00 Service 26.40 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County Postage .39 59.79 ? WELTMAN WEINBERG REIS 41 07/20/2006 Sworn and Subscribed to before me this day of , A. D. R. THOMAS KLINE Sheriff EDWARD L. SCHORPP Solicitor tv of CumbAtt" u lu OFFICE OF THE SHERIFF One Courthouse Square Carlisle, Pennsylvania 17013 RONNY R. ANDERSON Chief Deputy JODY S. SMITH Real Estate Deputy To: Pos stem (I , Agency Control No. Da ?p e199 i?(Vl?i w Date: - - l2.O6?, Address Information Request Please furnish this agency with the new address, if available, for the following individual or verify whether the address given below is one at which mail for this individual is currently being delivered. If the following address is a post office box, please furnish the street address as recorded on the box holder's application form , Name: / V COKE /M . Wt z Last Known Address: I- G S 12A AFT C4AAR-Pt-L) PA 170 t 1 I certify the address information for this individual is required for the performance of this agency's official duties. (Signature of Agency Of ial) &Oi4 ' (Title) For Post Office Use Only Ix Mail is delivered to address given. () Not Known at Address Given () Moved, Left No Forwarding Address () No Such Address () Other (Specify) Agency Return Address New Address Box holders' Street Address Postmark/Date Stamp Please fax results to the Cumberland County Sheriffs Office. Number (717) 240-6397 Address Information Request (Required format) Exhibit 352.44b R. THOMAS KLINE 1 Sheriff EDWARD L.SCHORPP Solicitor of Cuntbert5 OFFICE OF THE SHERIFF RONNY R. ANDERSON Chief Deputy JODY S. SMITH Real Estate Deputy One Courthouse Square Carlisle, Pennsylvania 17013 To: Postmaster Agency Control No. jrt Cam- Date: ?l Address Information Request Please furnish this agency with the new address, if available, for the following individual or verify whether the address given below is one at which mail for this individual is currently being delivered. If the following address is a post office box, please furnish the street address as recorded on the boxholder's application form. Name: Z- Last Known Address: I certify the address information for this individual is required for the performanceof?tiagency's official duties. ignature of .4(gepcfy Official) FOR POST OFFICE USE ONLY () MAIL IS DELIVERED TO ADDRESS GIVEN () NOT KNOWN AT ADDRESS GIVEN () MOVED, LEFT NO FOWARDING ADDRESS () NO SUCH ADDRESS O OTHER (SPECIFY): Agency Return Address Address Information Request (Required Format) Exhibit 352.44b NEW ADDRESS y?aa ? 6u,? ?, ?''r7 ol- 10 BOXHOLDERS' STREET ADDRESS Postmark / Date Stamp zE poi d z I inr goDl A 4 j J jN Hs ?rll A 3?I??J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAP7AL ONE BANK P aintiff VS W'\0 1i M LUTZ Defendant No 06-3308 CIVIL T =RM PRAECIPE_ TO REINSTATF COMPLAINT FILED ON BEHALF OF Pla miff COU?ASEL OE= RECORD 0;- I HIS PAR rY James C. Warmbrodt, 42524 WEL"fMAN, WEINBERG & REIS CO. L P.A. 436 Seventh Avenue. Suite 2718 Pittsburgh, PA 15219 (421) 434-7955 FAX: 412-338-7130 W VV R#05214734 v' IN THE COURT OF COMMON PLEAS CUM8ERLANC., COUNTY, PENNSYLVANIA CIVIL DIVISION CAP. AL ONE BANK Plaintiff vs NAO11 M LUTZ Defendant Civil Action No. 06-3808 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT Kindly rein State the Complaint in the above cc-3p Toned matter. WEL FMAN. VVI=INBERG & REIS CO L_P.A J?.mes C. Warmbrodt, 42524 By: WEL.TMAN, EINBERG & REIS CO., L.P.A 436 vent I venue, Suite 2718 Pittsburg , P 15219 (421) 43 -79 5 FA 412-338-7130 W WR #475214734 ice: -,rn IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. NAOMI ;LUTZ fendant No. 06-3808-CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOLCZAN, ESQUIRE PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05214734 Judgment Amount $ 2743.91 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. r f IN THE COURT OF COMI ON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION l CAPITALiONE BANK Plaintiff vs. Civil Action No. 06.3808-CIVIL TERM NAOMI M LUTZ Defendant PRAECIP.E FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, NAOMI M LUTZ above named, in the default of an Answer, in the amount of $2743.91 computed as follows: Amount claimed in Complaint $2535.71 Interest from JUN, 26, 2006 TO 14OVEMBER 18, 2006 a the legal intere t rate of 20.65°/ per annum $208.02 OTAL $274391 i I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By. WILLIAM T. MO C , ESQUIRE PA I.D.447437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05214734 Plaintiffs ddress is: c/o Weltrn in, Weinberg & R is Co., L.P.A., 2 18 Koppers Building, 436 7t' Avenue, Pittsburgh, PA 15219 And that t e last known addr ss of the Defendant is: 33 WILLIAM PENN DR AP 5, CAMP HILL,PA 17011 I r . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff NAOMI M LUTZ Defendant(s) IMPORTANT NOTICE TO: NAOMI M LUTZ 33 WILLIAM PENN DR AP 5 CAMP HILL,PA 17011 2 Date of Notice: -ow WWR## : 05214734 Case # 0(U - Gi I(t&m 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 BY: 1 it JAMOOPPERS BRODT, ESQUIRE PA 2524 WEL EINBERG & REIS CO., L.P.A. 271 BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Case no: 06-3808-CIVIL TERM Plaintiff vs. NON-MILITARY AFFIDAVIT NAOMI M LUTZ i Defendant T4 undersigned, who first being duly sworn, according to law, deposes and states as follows: Tli?t 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, NAOMI M LUTZ is not in the military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDQ, which states that the Defendant, NAOMI M LUTZ is not in the military service. Further Affiant sayeth naught. AFFIANT SUBSCRIBED in my presence this Z day ??.d6. C0MMONWllrA tH Clr PENNeY'LVA?NIA? Notaria Seal Wayne A. Jonas, Notary Public City Of Pifsburgh. Ailegtreny County My Commlssion Sxut HY June 29, 2010 Member, PennwvamE o;asociation 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 3? qtr a"- Military Status Report r b <, Pursuant to the Servicem mbers Civil Relief Act Page 1 of 2 NOV-18-2006 05:53:48 - Last Name First/Middle Begin bate Active Duty Status Service/Agency LUTZ NAOMI M 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. 1/1. &??_ 4wyl ?"4_ * Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The DcIense Manpower Data Center (pMDC) 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. i This res6onse reflects current active d ty status only. For historical information, please contact the See: http://www.defe nselinkm l/f4q/pis1PC09SLDR.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 11/18/2006 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 1D:7.WROPSBSIY https:// .dmdc.osd. nil/scra/owa/s ra.prc_Select 11/18/2006 ?a- t? 0 O 0 -J . .. msg ? _. _1 l -a IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. NAOMI LUTZ efendant NAOMI M LUTZ 33 WILLIAM PENN DR AP 5 CAMP HILL,PA 17011 Civil Action `'^ 06-3808-CIVIL TERM TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or J ment was entered against you on _ )9.4?/!f ,44306 (xx) Assumpsit Judgment in the amount of $2743.91 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 o Traffic Safety, Harrisburg, PA. ( x) Entry of Judgment of f ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By, PRO ONOTABY Plaintiff's address is: c/o Weltman, Weinberg & Reis Co. L.F.A., 2718 Koppers Building, 436 7`?' Avenue, Pittsburgh, PA 15219 1-888-434-0085 SHERIFF'S RETURN - REGULAR CASE NO: 2006-03808 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAPITAL ONE BANK VS LUTZ NAOMI M BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LUTZ NAOMI M the DEFENDANT , at 1820:00 HOURS, on the at 33 WILLIAM PENN DRIVE APT 5 CAMP HILL, PA 17011 NAOMI LUTZ by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 12.32 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 40.32./ 10/06/2006 1oll'sla ', WELTMAN WEINBERG REIS Sworn and Subscibed to By: before me this day Deputy Sheriff of , A.D. 5th day of October , 2006 /. A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. Civil Action No. 06-3808 CIVIL TERM NAOMI M LUTZ Defendant PSECU, Garnishee PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of CUMBERLAND County: 2. against NAOMI M LUTZ Defendant a s 'F.,,a i, , AP 17011 3. against PSECU, Garnishee aio ei&9e AVe, ShippehAcvS , PA 17x57 4. Judgment Amount $ 2743..91 - 229.3.9t/ Less payments of $ (350.00) Interest $ 39.24 Costs SUBTOTAL: Costs (to be added by Prothonotary): $ 2483.15 WELTMAN, WEINBERG & REIS CO., L.P.A. By: t.,A/ > William T. Molczan, squire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#5214734 0 ... 1. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. NAOMI M LUTZ Defendant PSECU, Garnishee, No. 06-3808 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#5214734 N 9 -?.. -b4- ° 9' c_ h r + F* r a ?, .44 o v o ? -,? 04 c-n C WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-3808 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CAPITAL ONE BANK, Plaintiff (s) From NAOMI M. LUTZ, 33 WILLIAM PENN DR AP 5, CAMP HILL, PA 17011 (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 PSECU, 210 RIDGE AVE., SHIPPENSBURG, PA 17257 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 $2393.91 Interest $39.24 Atty's Comm % Atty Paid $191.61 Plaintiff Paid Date: JULY 30, 2007 L.L. $.50 Due Prothy $2.00 Other Costs I C . Long, Pro otary (Seal) 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 By: Deputy Supreme Court ID No. 47437 R. Thomas Kline, Sheriff, who being duly sworn according to law, states + this writ is returned STAYED, ADDRESS PROVIDED IS A SELF SERVICE MACHINE, ALL BRANCHES ARE LOCATED IN DAUPHIN COUNTY. Sheriff's Costs: Advance Costs: 150.00 59.50 Docketing 18.00 $ 90.50 Poundage Advertising Law Library .50 Prothonotary 2.00 Refunded to Atty on 08/06/07 Mileage Surcharge 30.00 Levy Certified Mail Post Pone Sale Garnishee 9.00 Postage ,t,,? TOTAL $ 59.50 ? F?o Answers; , ?'' ,amt R. T omas Kline, Sheriff Ulawt, &zt,? By Claudia A. Brew baker J 9 ?p CIL t' 9 7 9' P ?c14g'3d a W 0 WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-3808 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due CAPITAL ONE BANK, Plaintiff (s) From NAOMI M. LUTZ, 33 WILLIAM PENN DR AP 5, CAMP HILL, PA 17011 (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 PSECU, 210 RIDGE AVE., SHIPPENSBURG, PA 17257 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 $2393.91 L.L. $.50 Interest $39.24 Atty's Comm % Atty Paid $191.61 Plaintiff Paid Due Prothy $2.00 Other Costs Date: JULY 30, 2007 (Seal) 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 Curtis .Long, Protho By: Deputy Ok IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. NAOMI M LUTZ Defendant PSECU, Garnishee TO THE PROTHONOTARY: Civil Action No. 06-3808 CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of DAUPHIN County: 2. against NAOMI M LUTZ, Defendant, 33 W i loam Perm Drive / Apt. 6, C'axnp gill, PA I-70 1) 3. against PSECU, Garnishee, I Credi+ Union dace, Aaxr1s;bur9, PA 17110 4. Judgment Amount $ 2741.91 Less payments of $ (350.00) Interest $ 39.24 Costs $ SUBTOTAL: $ 2483.15 Costs (to be added by Prothonotary): $ WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. Molczjn, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#5214734 9n w 03 ? cz? a n 0 C WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-3808 Civil CIVIL ACTION - LAW TO THE SHERIFF OF DAUPHIN COUNTY: , To satisfy the debt, interest and costs due CAPITAL ONE BANK, Plaintiff (s) From NAOMI M. LUTZ, 33 William Penn Drive/Apt. 5, Camp Hill, PA 17011 (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 GARNISHEE(S) as follows: PSECU, 1 Credit Union Place, Harrisburg, PA 17110 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 $2,483.15 Interest $39.24 Atty's Comm % Atty Paid $273.11 Plaintiff Paid Date: 10-10-07 (Seal) L.L. $.50 Due Prothy $2.00 Other Costs 3 Ljc L . C is R. Long, ProthonotaiFy By: Deputy REQUESTING PARTY: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., LPA 2718 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 47437 i 1< . , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff vs. NAOMI M LUTZ Defendant PSECU Garnishee No. 06-3808 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE & END AS TO THE GARNISHEE PSECU 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#5214734 r t? IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION CAPITAL ONE BANK Plaintiff VS. Civil Action No. 06-3808 CIVIL TERM NAOMI M LUTZ Defendant PSECU Garnishee PRAECIPE TO SETTLE DISCONTINUE AND END AS TO THE GARNISHEE, PSECU, ONLY TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue and End the above captioned matter as to Garnishee, PSECU, only, upon the records of the Court and mark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. ar br odt PA LD 4252 WEL AN, INBERG & REIS CO., L.P.A. E 271 Koppe Building 43 Seve Avenue P sbur , PA 15219 12) 4-7955 Sworn to and subscribed Before me the Da"f JANUAAV s'2 or-? LWWR#5214734 COMMONWEALTH OF PENNSYLVANIA Wendy L. Gaiulft INoW CRY of Pittsburgh, Allegheny C My Commission Expirot Jul 15 u01 Member, Pennsylvania Assoclat on o(?? Notariq ARY PUBLIC 003 c a -n r _ c r'F W _ _