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Home My WebLink About06-46864 t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. O` - 44A 0(oLt - Rn V S. COMPLAINT IN CIVIL ACTION MATTHEW ROBERT LARSON and ROBERT VERNON LARSON Defendants FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA LD #42524 WELTMAN, WEINBERG & REIS CO.. L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05309108 IN TI IE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. Q(e - l:cv?(, dg/i MATTHEW ROBERT L,ARSON and ROBERT VERNON I,ARSON Defendants 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 CANNOTAFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 4 COMPLAINT I . Plaintiff is a corporation with offices at 3311 Mill Meadow Drive, Hilliard, OH 43026. 2. Defendants are adult individuals residing at 2 Falcon CT., Mechanicsburg, PA. 17055. 3. Defendants applied for and received a credit card issued by Plaintiff bearing the account number 6011002270567076. 4. Defendants made use of said credit card and have currently a balance due and owing to Plaintiff, as of'.luly 28, 2006, in the amount of $2,435.75. 5. Defendants are in default of the terms of the cardholder Agreement having not made monthly payments to Plaintiff thereby rendering the entire balance immediately due and payable. 6. Plaintiff avers that the Agreement between the parties provides that Defendants will pay Plaintiffs attorneys' fees. 7. Plaintiff avers that such attorneys' fees will amount to $300.00. 8. Although repeatedly requested to do so by Plaintiff, Defendants have willfully failed and/or refused to pay the principal balance. finance charges or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendants, Matthew Robert Larson and Robert Vernon Larson jointly and severally, in the amount of $2,435.75 with interest at the legal interest rate of 6% per annum from date of judgment plus attorneys' fees of $300.00, and 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. P fLT AN, WEINBERG & REIS CO.. L.P.A. 18 oppers Building 6 eventh Avenue sburgh, PA 15219 .2) 434-7955 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unswom falsifications to authorities, that he is Robert Adkins, (Name) Accounts Manager of Discover Financial Services, LLC., plaintiff herein, that (Title) (Company) he is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of his/her knowledge, information and belief. (Signature) WWR# 5309108 MATTHEW ROBER LARSON 6011002270567076 70 it- CJ 0`) 46a V C 1 c` N O O T a c c-? cn x> 0 w cn Q C3 r? J ?c np, y ,,, SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-04686 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DISCOVER BANK VS LARSON MATTHEW ROBERT ET AL 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 T.ARgnl\T MATTWRW RnPRPT but was unable to locate Him in his bailiwick. He therefore returns the NOTICE COMPLAINT the within named DEFENDANT 2 FALCON COURT NOT FOUND , as to LARSON MATTHEW ROBERT MECHANICSBURG, PA 17055 DEFENDANT COULD NOT BE LOCATED AT ADDRESS PROVIDED PRIOR TO EXP. DATE, RETURN NOT FOUND PER WAYNE, ATTY WARMBRODTS OFFICE 9/18/06 Sheriff's Costs: So answers - Docketing 18.00 Service 8.80-?? NOT FOUND RETURN 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County -- . - v 9-aa-v4 9- Sworn and Subscribed to before me this day of WELTMAN, WEINBERG & REIS 09/18/2006 A. D. SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-04686 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DISCOVER BANK VS LARSON MATTHEW ROBERT ET AL 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 LARSON ROBERT VERNON but was unable to locate Him in his bailiwick. He therefore returns the NOTICE COMPLAINT , NOT FOUND , as to the within named DEFENDANT , LARSON ROBERT VERNON 2 FALCON COURT MECHANICSBURG, PA 17055 DEFT COULD NOT BE LOCATED AT ADDRESS PROVIDED PRIOR TO EXP DATE RETURN NOT FOUND PER WAYNE AT ATTY WARBRODTS OFFICE 9/18/06 Sheriff's Costs: Docketing Service NOT FOUND RETURN Surcharge 6.00 .00 5.00 10.00 Sworn and Subscribed to before me this day of So answers: le, R. Thomas Kline Sheriff of Cumberland County WELTMAN, WEINBERG & REIS 09/18/2006 A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. No. 06-4686-CIVIL-TERM MOTION FOR ALTERNATE SERVICE MATTHEW ROBERT LARSON ROBERT VERNON LARSON Defendants 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 #05309108 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. MATTHEW ROBERT LARSON ROBERT VERNON LARSON Defendants No. 06-4686-CIVIL-TERM PLAINTIFF'S MOTION FOR ALTERNATE SERVICE AND NOW, comes Plaintiff, by counsel, Weltman, Weinberg & Reis Co., L.P.A. and requests this Honorable Court to enter an Order allowing the Plaintiff to make service upon Defendants, MATTHEW ROBERT LARSON AND ROBERT VERNON LARSON, by certified U.S. Mail and Certificate of Mailing, addressed to 2 Falcon Ct, Mechanicsburg,Pa 17055, averring in support thereof the following: 1. On or about AUGUST 15, 2006, Plaintiff filed a Complaint in Civil Action against Defendants to recover the unpaid balance due Plaintiff from Defendants in the amount of $2435.75. 2. When the Sheriff of CUMBERLAND County, Pennsylvania, attempted to make service of Plaintiff's Complaint on Defendants, the Sheriff was unable to do so, as evidenced by the Sheriff's return, a true and correct copy of which is attached hereto, marked Exhibit "I", and made a part hereof. 3. Upon receipt of the Sheriff's return of no service, Plaintiff conducted an investigation with the United States Postal Service to confirm the physical address of the Defendants. WWR #05309108 4. Pursuant to Plaintiffs request for information, the United States Postal Service confirmed Defendant's physical address of 2 Falcon Ct, Mechanicsburg,Pa 17055, a true and correct copy of Plaintiff's Postal Request is attached hereto, marked as Exhibit "2", and made a part hereof. 5. Plaintiff conducted an online white pages search and was unable to confirm a current address for Defendants of 2 Falcon Ct, Mechanicsburg,Pa 17055. 6. Plaintiff contacted the CUMBERLAND County Tax Assessment office, a representative from which could not confirm the Defendant's current physical address as 2 Falcon Ct, Mechanicsburg,Pa 17055. 7. Plaintiff requested information from the Department of Motor Vehicles for Defendants and there are vehicles registered to Defendant, Matthew Robert Larson, at 2 Falcon Ct, Mechanicsburg,Pa 17055. A true and correct copy of the Motor Vehicle Abstract is attached hereto, marked as Exhibit "3", and made a part hereof. 8. Based upon the foregoing, Plaintiff believes and therefore avers that Defendants are attempting to avoid service of process in the above-captioned matter and Plaintiff therefore seeks an Order of Court, pursuant to Pennsylvania Rule of Civil Procedure 430, granting Plaintiff leave to serve its Complaint on Defendants by alternative means. WWR #05309108 WHEREFORE, Plaintiff requests this Honorable Court to enter an Order pursuant to PA.R.C.P. 430(a), authorizing the Plaintiff to serve Defendants by Certified U.S. Mail and Certificate of Mailing sent to an address (2 Falcon Ct, Mechanicsburg,Pa 17055) at which Defendants are presently receiving mail according to information obtained from the Post Office, or by allowing service by a competent adult. William T. Molczan, quire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #05309108 SHERIFF'S RETURN - NOT FOUND LASE NO: 2006-04686 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DISCOVER BANK LARSO MATTHEW ROBERT E 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 LARSON MATTHEW ROBERT but was unable to locate Him in his bailiwick. He therefore returns the NOTICE COMPLAINT NOT FOUND , as to the within named DEFENDANT , LARSON MATTHEW ROBERT 2 FALCON COURT MECHANICSBURG, PA 17055 DEFENDANT COULD NOT BE LOCATED AT ADDRESS PROVIDED PRIOR TO EXP. DATE, RETURN NOT FOUND PER WAYNE, ATTY WARMBRODTS OFFICE 9/18/06 Sheriff's Costs: So answers- Docketing 18.00 --` Service 8.80 NOT FOUND RETURN 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County nn 41.80 WELTMAN, WEINBERG & REIS 09/18/2006 Sworn and Subscribed scrbed to before E me this day of , A. D. SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-04686 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DISCOVER BANK VS LARSON MATTHEW ROBERT ET AL 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 LARSON ROBERT VERNON but was unable to locate Him in his bailiwick. He therefore returns the NOTICE COMPLAINT the within named DEFENDANT 2 FALCON COURT NOT FOUND , as to , LARSON ROBERT VERNON MECHANICSBURG, PA 17055 DEFT COULD NOT BE LOCATED AT ADDRESS PROVIDED PRIOR TO EXP DATE RETURN NOT FOUND PER WAYNE AT ATTY WARBRODTS OFFICE 9/18/06 Sheriff's Costs: So answers: Docketing 6.00 Service .00 NOT FOUND RETURN 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County r% r% WELTMAN, WEINBERG & REIS 09/18/2006 Sworn and Subscribed to before me this day of A. D. 1 ?? W ELTMAN, W EINBERG & REIS Co., L.P.A. ATTORNEYS AT LAW 2718 Koppers Building 436 Seventh Avenue Pittsburgh, Pennsylvania 15219 412.434.7955 www.weltman.com WILLIAM T. MOLCZAN Attorney at Law 412.434.7955 2--D Fax 412.434.7959 OF INNOVATION wmoiczan@weltman.com GROWTH + RESULTS September 18, 2006 Postmaster MECHANICSBURG,PA 17055 Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please fumish the new address or the name and street address (if a box-holder) for the following: Name: ROBERT VERNON LARSON Address: 2 FALCON CT MECIIANICSBURG,PA 17055 BURLINGTON, NJ 609.914.0437 CHICAGO, IL 847.940.9812 CINCINNATI, OH 513.723.2200 CLEVELAND,OH 216.685.1000 COLUMBUS, OH 614.228.7272 DETROIT, MI 248.362.6100 PHILADELPHIA, PA 215.599.1500 NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(d)(1) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester: William T. Molezan, Esquire. Attorney for Plaintiff, DISCOVER BANK 2. Statute or regulation that empowers me to serve process : N/A 3. The names of all known parties to the litigation: DISCOVER BANK vs. ROBERT VERNON LARSON 4. The Court in which the case has been or will be heard: Court of Common Pleas of CUMBERLAND 5. The docket or other identifying number if one has been issued: 06-4686-CIVIL-TERM The capacity in which this individual is to be served: Defendant WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOX-HOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OF (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation. Wa e A. Jones WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh. PA 15219 FOR POST BOXHOLDER'S POSTMARK Not known at address given. s -Moved, left no forward address. G? V'- EkW31T No such address. No change of address on file Good as Addressed 2- XXX PLEASE INDICATE PHYSICAL ADDRESS NEW ADDRESS or NAME and STREET ADDRESS WW R#05309108 WELTMAN, WEINBERG & REIS CO., L.P.A. ATTORNEYS AT LAW WILLIAM T. MOLCZAN Attorney at Law 412.434.7955 Fax 412.434.7959 wmoiczan@weltman.com 2718 Koppers Building 436 Seventh Avenue Pittsburgh, Pennsylvania 15219 412.434.7955 www.weltman.com ?? OF INNOVATION GROWTH + RESULTS September 18, 2006 Postmaster MECHANICSBURG,PA 17055 Request for Change of Address or Boxholder Information Needed for Service of Legal Process Please furnish the new address or the name and street address (if a boxholder) for the following: Name: MATTHEW ROBERT LARSON Address: 2 FALCON CT MECHANICSBURG,PA 17055 BURLINGTON, NJ 609.914.0437 CHICAGO, IL 847.940.9812 CINCINNATI, OH 513.723.2200 CLEVELAND,OH 216.685.1000 COLUMBUS, OH 614.228.7272 DETROIT, MI 248.362.6100 PHILADELPHIA, PA 215.599.1500 NOTE: The name and last known address are required for change of address information. The name, if known, and post office box address are required for boxholder information. The following information is provided in accordance with 39 CFR 265.6(d)(6)(ii). There is no fee for providing boxholder information. The fee for providing change of address information is waived in accordance with 39 CFR 265.6(dx I) and (2) and corresponding Administrative Support Manual 352.44a and b. 1. Capacity of requester: William T. Molezan Esquire. Attorney for Plaintiff, DISCOVER BANK 2. Statute or regulation that empowers me to serve process : N/A 3. The names of all known parties to the litigation: DISCOVER BANK vs. MATTHEW ROBERT LARSON 4. The Courtin which the case has been or will be heard: Court of Common Pleas of CUMBERLAND 5. The docket or other identifying number if one has been issued: 06-4686-CIVIL-TERM The capacity in which this individual is to be served: Defendant WARNING THE SUBMISSION OF FALSE INFORMATION TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERVICE OF LEGAL PROCESS IN CONNECTION WITH ACTUAL OR PROSPECTIVE LITIGATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRISONMENT OF (2) TO AVOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001). I certify that the above information is true and that the address information is needed and will be used solely for service of legal process in connection with actual or prospective litigation. WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue W ne A. Jones Pittsburgh, PA 15219 FOR POST OFFICE USE ONLY BOX.HOLDER'S POSTMARK thiSIT Not known at address given. _Moved, left no forward address. No such address. _--- No change of address on file XGood as Addressed XXX PLEASE INDICATE PHYSICAL ADDRESS .4G PA 27Qs NEW ADDRESS or NAME and STREET ADDRESS 5w '?' `s`ue W W R#05309108 PENNSYLVANIA DEPARTMENT OF TRANSPORTATION VEHICLE RECORD ABSTRACT 11/14/06 PAGE 1 276002 OWNER MATTHEW R LARSON 2 FALCON CT MECHANICSBURG PA 17055 TITLE NUMBER : 55042096 TAG NUMBER : GDT6348 VIN : WDBDA29D6KF570115 MAKE : MERCEDES BENZ MODEL : 2.6 RENEWAL WID : 062201015000370 001 PREVIOUS TAG : DVK4102 LIENS : YES STOPS : NO 063180713000540 005 LESSEE : NONE TITLE DATE : 08/10/00 REGISTRATION EXPIRY DATE: 08/07 BODY TYPE SDN ODOMETER READING *EXEMPT BY FED LAW DUPLICATE TITLE COUNT 0 VEHICLE YEAR 1989 STOLEN DATE TITLE BRAND INFORMATION NO TITLE BRANDS EXIST FOR THIS TITLE LIEN INFORMATION LIEN HOLDER NO. 1 NAME : NEW KINGSTOWN AUTO SALES INC ADDRESS: 73 EAST MAIN ST EXPIRATION DATE: 11/08/11 PO BOX 413 ABA NO : NEW KINGSTOWN PA 17072 ELT IND: NO 2ND OR 3RD LIENS EXIST FOR THIS TITLE ADDRESS CORRESPONDENCE TO: DEPARTMENT OF TRANSPORTATION VEHICLE RECORD SERVICES PO BOX 68691 HARRISBURG, PA 17106-8691 INFORMATION: (8:00 AM TO 6:00 PM) IN STATE 1-800-932-4600 OUT-OF-STATE 717-412-5300 TDD IN STATE 1-800-228-0676 TDD OUT-OF-STATE 717-412-5380 WWW.DOT.STATE.PA.US a_S r (C)48 CERTIFICATE OF SERVICE The undersigned certifies that a true and correct copy of the within Motion for Alternate Service was served on the I day of e- , 2006, by first class, U.S. Mail, postage-prepaid, addressed as follows: MATTHEW ROBERT LARSON AND ROBERT VERNON LARSON 2 Falcon Ct Mechanicsburg,Pa 17055 ", Attorney or Plaintiff WWR #05309108 A . i r. , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. MATTHEW ROBERT LARSON ROBERT VERNON LARSON Defendants NO. 06-4686-CIVIL-TERM AFFIDAVIT PURSUANT TO PA R.C.P. 430 (a) BEFORE ME, a Notary Public, in and for the foregoing County and Commonwealth, personally appeared William T. Molczan, Esquire, of Weltman, Weinberg & Reis, Co., L.P.A., attorneys for Plaintiff, and deposes and says that the following accurately reflects efforts made to ascertain the exact whereabouts of Defendant named in the above-captioned matter. a. Plaintiff requested current address information from the United States Postal Service, which request for information confirmed the current address for Defendants as being 2 Falcon Ct, Mechanicsburg,Pa 17055. A true and correct copy of the Postal Service Return is marked Exhibit "2" attached hereto and made a part hereof. b. Plaintiff requested a vehicle search on the Defendants, which shows that the Defendant, Matthew Robert Larson, has a registered vehicle at 2 Falcon Ct, Mechanicsburg,Pa 17055. A true and correct copy is attached hereto and marked as Exhibit "3". WWR #05309108 M 4 . , 1 Finally, Affiant deposes and says that after the foregoing investigation, the exact whereabouts of the Defendants, MATTHEW ROBERT LARSON AND ROBERT VERNON LARSON, is 2 Falcon Ct, Mechanicsburg,Pa 17055. WELTMAN, WEINBERG & REIS, CO., L.P.A. j l William T. Molczan, Esqu' PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 Sworn to and subscribed before me this 30 day November, 06 A?'111- 01 Nohrled >9eel '0kV* a Jones, Nawy Public NhrE ? ?o MffrhW,PWmvivan!a Association of WNW WWR #05309108 f^ e s. ?{ Fri (fa CA +a? a _ t v IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA zfJ06 CIVIL DIVISION DISCOVER BANK Plaintiff VS. MATTHEW ROBERT LARSON ROBERT VERNON LARSON No. 06-4686-CIVIL-TERM ORDER OF COURT 1h AND NOW, to-wit, this day of O ?, • , 2006, upon consideration of the foregoing Motion for Service of the Complaint Pursuant to Special Order of Court and attached supporting affidavit, it is hereby ORDERED, ADJUDGED AND DECREED, that the service of the Complaint in Civil Action may be made on Defendants, MATTHEW ROBERT LARSON AND ROBERT VERNON LARSON, by permitting the Plaintiff to mail a copy of the Complaint to the Defendants the last known address being 2 Falcon Ct, Mechanicsburg,Pa 17055 by Certified Mail and by Certificate of Mailing Postal Form 3817, postage prepaid. Service to be completed upon mailing. BY THE COURT: WWR #05309108 ii t 4`??t?111g tr+','?''1t+ gooz L-1--lb.10314 O ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER SAND Plaintiff vs, MATTHEW ROBERT LARSON ROBERT VERNON LARSON Defendant No. 064686-CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, 42624 WELTMAN, WEINBERO & REIS CO., L.P.A, 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (421) 434-7955 FAX: 412-3387130 WWR#05309108 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 06-4686-CIVIL TERM MATTHEW ROBERT LARSON ROBERT VERNON LARSON Defendant PRAECIPE TQ REINSTATI* CQMP AINT Kindly reinstate the Complaint in the above captioned mutter. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. Warmbrodt, 42524 BERG & REIS CO., L.P.A. 436 Sev ue, Suite 2718 WELTMA )?PA219 Pittsbur h(421) 4, F 338-7130 R #05309108 e--? p i - ?} t ?, ? -? r -n `t ry ? N J . • ? f?- . ? , "" ' ? ? . 1 f .5 .. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. MATTHEW ROBERT LARSON ROBERT VERNON LARSON Defendant No. 06-4686-CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, 42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (421) 434-7955 FAX: 412-338-7130 W W R#05309108 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 06-4686-CIVIL TERM MATTHEW ROBERT LARSON ROBERT VERNON LARSON Defendant PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By: / / James C. Warmbrodt, 42524 WELTM \ INBERG & REIS CO., L.P.A. 436 Sev nth enue, Suite 2718 Pittsbur h, P 15219 (421) 4-79 5 F .412-338-7130 08 r?a ° ? ? ?? .? ` ' ` ? '?' _ ? "? ji`?^i '' ?? tq y t _? ? ? y ? am-"- a...,, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. MATTHEW ROBERT LARSON ROBERT VERNON LARSON Defendants No. OL-',/W L AFFIDAVIT OF SERVICE OF COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA. I.D.947437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05309108 46 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. vs. MATTHEW ROBERT LARSON ROBERT VERNON LARSON Defendants AFFIDAVIT OF SERVICE OF COMPLAINT BEFORE ME, the undersigned authority, personally appeared William T. Molczan, Esquire, who according to law deposes and says that a copy of the Complaint in Civil Action has been served on the Defendants, MATTHEW ROBERT LARSON AND ROBERT VERNON LARSON. 1. On or about DECEMBER 11, 2006, Plaintiff received a signed Order of Court permitting service, on the Defendant, to be complete and valid upon mailing to the complaint by first class mail, certificate of mailing and by certified mail, return receipt requested. Said Order of Court is attached as Exhibit "I". 2. On or about MARCH 21, 2007, 2007 Plaintiff mailed the complaint to 2 FALCON CT, MECHANICSBURG, PA 17055 . Said certificate of mailing and certified mail receipts are attached as Exhibit "2". WELTMAN, WEINBERG & REIS, CO., L.P.A. i / ". lz 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#05309108 Sworn to and before meAhi 2005. ARY Gvf liJUiVV1i H?+ , vr NSYLVANIA L Not, 77d Seal Heidi J. Kei!y, Natary Public City Of Pittska;'i=;h, a°egheny County My Commi :' .:" Nov. 4, 2009 ci ?i?m of Notaries Member. (EC 0 6 2006 ?? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION e?- DISCOVER BANK Plaintiff VS. MATTHEW ROBERT LARSON ROBERT VERNON LARSON No. 06-4686-CIVIL-TERM ORDER OF COURT AND NOW, to-wit, this day of 2006, upon consideration of the foregoing Motion for Service of the Complaint Pursuant to Special Order of Court and attached supporting affidavit, it is hereby ORDERED, ADJUDGED AND DECREED, that the service of the Complaint in Civil Action may be made on Defendants, MATTHEW ROBERT LARSON AND ROBERT VERNON LARSON, by permitting the Plaintiff to mail a copy of the Complaint to the Defendants the last known address being 2 Falcon Ct, Mechanicsburg,Pa 17055 by Certified Mail and by Certificate of Mailing Postal Form 3817, postage prepaid. Service to be completed upon mailing. BY THE COURT: 51.rn 4. pj'w_aIjj. TRUE COPY FR(W RECORD In Testimony whereof, '. h fa uiito set my hand EXHIBIT and the seal of said Cour t rlisle, Pa. ' TA ..... da of ?... WWR #05309108 a . , MAILI U.S. POSTAL SEpyICE CERTIFICA?E.OF MAILING ' r 6 MEVATiONAL W11- DOES 1OT AND N r n' JAY BE UFO R DOMES't>C j c c r RWIDE llP.Rh?E"P0.iTI/45TER _ 73 m?<vd 436 71h Avam'e a? r races.. =• y` y _ co O (412) 434-79-? n? ; O iaT CO U- d adv'ary R"i add+J Ct/d v?p5 Yd - v One piece ? Y5?311NI1 0 C?' ? r, } PS Form 3817. January 2001 U.S. Postal Service,M CERTIFIED MAIL:, RECEIPT (Domestic Mail Only; No Insurance Coverage Provided) O - Er CO Postage S C3 Certified Fee Z C Q Return Recei? Fee (Endorsement Requked) Q ? Restricted Delivery Fee (Endorsement ROQUWW) m Total Postage & Fees O ?0 70 lard u5p5 Ln r3 ant oLcC.?..L?1.[.._L.?X.C:c e?--r•-- ""?`?.-._.?_` ?'_, os nro. C..1..?.?.=---- r ----- ..F?.? PS Form 3800. June 2002 See Reverse for Instructio EXHIBIT % ?Z t %too IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. No. 06-4686 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT MATTHEW ROBERT LARSON and ROBERT VERNON LARSON Defendants 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#05309108 Judgment Amount $ 2.735.75 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 DISCOVER BANK Plaintiff vs. MATTHEW ROBERT LARSON and ROBERT VERNON LARSON Defendants Civil Action No. 06-4686 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendants, MATTHEW ROBERT LARSON and ROBERT VERNON LARSON, above named, in the default of an Answer, in the amount of $2.735.75 computed as follows: Amount claimed in Complaint $2,435.75 Interest from date of judgment at the legal interest rate of 6% per annum Attorney's fees $300.00 TOTAL $2.735.75 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. e, L) fy.'A 0ec COUNTY, PENNSYLVANIA CIVIL DIVISION William T. Molczan, E54uire PA I. D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05309108 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendants is: 2 FALCON CT, MECHANICSBURG, PA 17055 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff ROBERT VERNON LARSON Defendant(s) IMPORTANT NOTICE TO: ROBERT VERNON LARSON 2 FALCON CT MECHANICSBURB,PA 17055 Date of Notice: WWR#: 05309108 Case # I01 C- T?--)?XH 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%/I I.C?W?YN.Oa PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff MATTHEW ROBERT LARSON Defendant(s) IMPORTANT NOTICE TO: MATTHEW ROBERT LARSON 2 FALCON CT MECHANICSBURG,PA 17055 Date of Notice: WWR#: 05309108 Case # 9I nl;li 0-C 1,1)L.TEJ2,`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 BY: 'i?'LtAfRi? PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 IN THE COMMON PLEAS COURT OF COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs MATTHEW ROBERT LARSON and ROBERT VERNON LARSON Defendant Case no: 06-4686 CIVIL TERM NON-MILITARY AFFIDAVIT 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, MATTHEW ROBERT LARSON and ROBERT VERNON LARSON 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, MATTHEW ROBERT LARSON and ROBERT VERNON LARSON is not in the military service. Further Affiant sayeth naught. AFFIANT SWORN TO DS SCRIBED in my presence this\ day COMMONWEALTH OF PENNSYLVANIA Notarial Seel NOTA PUBLIC Were,. '..Gaunt.' .,ar&ublic CityOf pi' .,3urgh,, a henyCounty 1 _ MY Comr- :sion Expo, July 15, 2010 Member, Pennsylvania Associatior, of Notariie, 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 4D Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 MAY-01-2007 05:19:25 -C Last Name First/Middle Begin Date Active Duty Status Service/Agency LARSON MATTHEW 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. y6t Jr4. V"Ai_ A?M_ 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. See: httt://www.defenselink.mil/faq/pis/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 5/l/2007 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: VXTEKEPIHG https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 5/l/2007 Request for Military Status Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 MAY-01-2007 05:19:47 -< Last Name First/Middle Begin Date Active Duty Status Service/Agency LARSON ROBERT 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. #Wt Jrn 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. See: http://www.defenselink.mil/faq/pis/PC09SLDR.html 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 5/l/2007 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: VXKBELQTTS https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 5/1/2007 ?. 0 ? ? ? ? ? ? ? ? ?...? r ?? tiro ?'? 't'i r? `?':; _.s --t -?'" 'T: t F? _... ?? ??. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 06-4686 CIVIL TERM MATTHEW ROBERT LARSON and ROBERT VERNON LARSON Defendants NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judgment was entered against you on t ?7 (xx) Assumpsit Judgment in the amount of $2.735.75 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 By: PROTHONOTARY MATTHEW ROBERT LARSON 2 FALCON CT MECHANICSBURG,PA 17055 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 06-4686 CIVIL TERM MATTHEW ROBERT LARSON and ROBERT VERNON LARSON Defendants NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judgment was entered against you on __Mxs, or-20x7 (xx) Assumpsit Judgment in the amount of $2.735.75 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 By: PWY PROTHONOTARY ROBERT VERNON LARSON 2 FALCON CT MECHANICSBURB, PA 17055 J 16 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. MATTHEW ROBERT LARSON ROBERT VERNON LARSON Defendants No. 06-4686-CIVIL-TERM PRAECIPE FOR SATISFACTION OF 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 Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05309108 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. MATTHEW ROBERT LARSON ROBERT VERNON LARSON Defendants Civil Action No. 06-4686-CIVIL-TERM PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. Sworn to and subscribed before me tft 3a day of Se to r!:?S NO ARY PUB IC WELTMAN, WEINBERG & REIS CO., L.P.A. By: 6x .)- William T. Molczan, E?RGire PA. I . D.#47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #05309108 COMMMONW& rh u_ PENNSYLVANIA Noted ts" -? Wendy L CaA Notar, p?,.:,±' , Uy C Nttsburgh, AIIe ,r ray ?; pt:t?'?;1 My ?r,,t ?:.?ston E?ir?„?u IY 11 ? 2t1'1 J f L Gr ? ? C7 r. MM {?' t7 ? 0 f 5