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)
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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
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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
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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
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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
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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
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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
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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
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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
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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
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