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HomeMy WebLinkAbout06-7075 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: Q` ?b z vs. COMPLAINT IN CIVIL ACTION DOMINIC M KNIPFING Defendant 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 (412) 434-7955 FAX: 412-338-7130 05570471 C A Pit WLG IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No DOMINIC M KNIPFING Defendant COMPLAINT 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. 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 COMPLAINT 1. Plaintiff, is a corporation with offices at 6500 NEW ALBANY ROAD NEW ALBANY , OH 43054 . 2. Defendant is adult individual(s) residing at the address listed below: DOMINIC M KNIPFING 311 FARMINGTON DR SHIPPENSBURG, PA 17257 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011002850733338 . A copy of Plaintiff's Statement of Account s attached hereto, marked as Exhibit "A" and made a part hereof. 4. Defendant made use of said credit card and currently has a balance due and owing to Plaintiff, as of November 28, 2006 , in the amount of $5453.68 . 5. Defendant is in default by failing to make payments when due. 6. Plaintiff avers that the Agreement between the parties provides that Defendant will pay Plaintiff's attorneys' fees. 7. Plaintiff avers that such attorneys' fees will amount to $500.00 . 8. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for Judgment in its favor and against Defendant , DOMINIC M KNIPFING INDIVIDUALLY , in the amount of $5453.68 with interest at the legal rate of 6.000W per annum from date of judgment plus attorneys' fees of $500.00 , and costs. James Warmbrodt,42524 WELT WEINBERG & REIS CO., L.P.A. 436 eve th Avenue, Suite 2718 Pit bur h, PA 15219 (41 ) 43 -7955 F 41 -338-7130 05 704 1 C A Pit WLG This law firm is a debt collector at mp ing to collect this debt for our client and any information obtai e will be used for that purpose. DISCOVER CARD 15 SDSN6A01 0007490 DOMINIC KNIPFING 311 FARMINGTON DR SHIPPENSBURG PA 17257-2041 $5,453.68 Enter Amount Enclosed Below Payment Due Date October 14, 2006 Please make check payable to Discover Gold Card. Minimum payment due includes a past due AX (A amount of $1,314.00. Save time and a stamp this month by paying your bill online. To find out about our free and flexible online payment features, visit Discovercard.com/payments G -1 ,5" PO BOX 15251 Ill,ullnun111111nlnll WILMINGTON DE 19886-5251 Address, e-mail or telephone change? Print change in space above, or go to Discovercard.com. Print your e-mail address to receive important Account information and special offers. 000006011002850733338054536800000000545368 Discover Gold Card Account Summary Closing Date: September 15, 2006 page 1 of 1 ;Account Number 6011 0028 5073 3338 Previous Balance $5,453.68 ;Payment Due Date October 14, 2006 Payments And Credits - 0.00 Minimum Payment Due $5,453.68 Purchases + 0.00 Credit Limit $3,895.00 Cash Advances + 0.00 Credit Available $-1,558.00 Balance Transfers + 0.00 :Cash Credit Limit $0.00 Cash C dit A il bl $0 00 I Finance Charges l + 0.00 re va a e . New Ba ance m $5,453.68 'Cashback Bonus Opening Cashback Bonus Balance $ 0.00 New Cashback Bonus Earned + 0.00 Cashback Bonus Balance $ 0.00 Cashback Bonus® Anniversary Available to Redeem $ 0.00 Date: July 15 How Can We Help You? For Account Inquiries, write to us at Discover Gold Card, PO Box 30943 Please have your Discover Card available. Salt Lake City, UT 84130 Manage your account online at Discovercord.com TDD (Telecommunications Device for the Deaf): ,Customer Service: 1-800-DISCOVER (1-800-347.2683) For assistance, see reverse side. 'Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence. Information For You The address provided in your Cardmember Agreement to request a beneficiary designation form for your Scheduled Air Travel Accident Insurance has changed. The new address is AIG Accident & Health Division, 300 South Riverside Plaza, Suite 2100, Chicago, Illinois 60606-6613. Shop confidently. Your Discover(R) Card has you covered with Complete Fraud Protection for your peace of mind. With our advanced fraud warnings, we'll call you right away if there's unusual activity on your account. And if someone makes fraudulent charges with your card, our $0 fraud liability guarantee means you're not responsible. Finance Charge Summary Nominal Transaction Average Daily ANNUAL ANNUAL Periodic Fee Daily Periodic PERCENTAGE PERCENTAGE FINANCE FINANCE Balances Rates RATES RATES CHARGES CHARGES VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unsworn 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 # 5570471 DOMINIC M KNIPFING 6011002850733338 lJ L rn -rt G -? Fri N 'C ? C.I1 ? N U(4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. DOMINIC M KNIPFING Defendant No. 06-7075 CIVIL TERM MOTION FOR ALTERNATE SERVICE FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire Pa I.D. No. 42524 Weltman, Weinberg & Reis, Co., LLC 2718 Koppers Building 436 Seventh Avenue Pittsburgh PA 15219 412-434-7955 WWR #05570471 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 06-7075 CIVIL TERM VS. DOMINIC M KNIPFING Defendant 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 Defendant, DOMINIC M KNIPFING, by certified U.S. Mail and Certificate of Mailing, addressed to 311 Farmington Dr, Shippensburg,Pa 17257 , averring in support thereof the following: 1. On or about DECEMBER 12, 2006, Plaintiff filed a Complaint in Civil Action against Defendant to recover the unpaid balance due Plaintiff from Defendant in the amount of $5453.68. 2. When the Sheriff of CUMBERLAND County, Pennsylvania, attempted to make service of Plaintiff's Complaint on Defendant, 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 "1", and made a part hereof. 3. Upon receipt of the Sheriffs return of no service, Plaintiff conducted an investigation with the United States Postal Service to confirm the physical address of the Defendant. WWR #05570471 4. Pursuant to Plaintiff's request for information, the United States Postal Service confirmed Defendant's physical address of 311 Farmington Dr, Shippensburg,Pa 17257 , 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 Defendant of 311 Farmington Dr, Shippensburg,Pa 17257. 6. Plaintiff contacted the CUMBERLAND County Tax Assessment office, a representative from which could not confirm the Defendant's current physical address as 311 Farmington Dr, Shippensburg,Pa 17257. 7. Based upon the foregoing, Plaintiff believes and therefore avers that Defendant is 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 Defendant by alternative means. WWR #05570471 WHEREFORE, Plaintiff requests this Honorable Court to enter an Order pursuant to PA.R.C.P. 430(a), authorizing the Plaintiff to serve Defendant by Certified U.S. Mail and Certificate of Mailing sent to an address (311 Farmington Dr , Shippensburg,Pa 17257 ) at which Defendant is presently receiving mail according to information obtained from the Post Office, or by allowing service by a competent adult. James C. rmbrodt, Esquire Pa I.D. o. 2524 Weltm n, Weinberg & Reis, Co., LLC 2718 oppers uilding 436 eventh enue Pitt urgh PA 15219 41 434-795 WWR #05570471 SHERIFF'S RETURN - NOT FOUND OASE NO: 2006-07075 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DISCOVER BANK VS KNIPFING DOMINIC 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 KNIPFING DOMINIC M but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , the within named DEFENDANT NOT FOUND , as to KNIPFING DOMINIC M I 311 FARMINGTON DRIVE SHIPPENSBURG, PA 17257 PER OFFICE, DEFENDANT NO LONGER LIVES AT GIVEN ADDRESS. NO FORWARDING ON FILE AT POST OFFICE. Sheriff's Costs: So answers: _ Docketing 18.00 Service 17.60 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 So.60 WELTMAN WEINBERG REIS 12/18/2006 Sworn and Subscribed to before EN8O me this day of A.D. -- W ELTMAN, W EINBERG & REIS Co., L.P.A. ATTORNEYS AT LAW WILLIAM T. MOLCZAN Attorney at Law 412.434.7955 Fax 412.434.7959 wmoiczan@weltman.com Postmaster SHIPPENSBURG,PA 17257 January 5, 2007 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: DOMINIC M KNIPFING Address: 311 FARMINGTON DR SI IIPPENSBURG,PA 17257 BURLINGTON, NJ 609.914.0437 CHICAGO, IL 847.940.9812 CINCINNATI, OR 513.723.2200 CLEVELAND,OH 216.685.1000 COLUMBUS, OR 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 tee 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 Ar'ministrative Support Manual 352.44a and b. 1 . Capacity ofrequester: 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. DOMINIC M KNIPFING 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: : 06-7075 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 TI IAN 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 TI [AN 5 YEARS, OR BOTH (TITLE 18 U.S.C. ,ECEION 1001). 1 certit},, that the above information is true and that the address information is needed and will be u?-cd solely for service of legal process in connection With actual or prospective litigation. Mn rSdale WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 I FOR POST OFFICE USE ONLY BOXHOLDER'S POSTMARK Not known at address given. -Moved. left no forward address- No such address. No chanac of address on tile. 3ood as Addre,sed XXX PLEASE; INDICATE PHYSICAL ADDRESS NEW ADDRESS or NAME and STREET ADDRESS 17 F? kf t a.: :qv" cn ?a 4 6 ;c. (mil 1- 1?. (1)n, Z 92 5 1,21 r'?f7?2? WWR#05570471 2718 Koppers Building 436 Seventh Avenue Pittsburgh, Pennsylvania 15219 412.434.7955 www.weltman.com Z'?zo ' 00, (/ OF INNOVATION GROWTH + RE5 ULT5 CERTIFICATE OF SERVICE The undersigned certifies that a true and correct copy of the within Motion for Alternate Service was served on the 13 day of of , 2007, by first class, U.S. Mail, postage-prepaid, addressed as follows: DOMINIC M KNIPFING 311 Farmington Dr Shippensburg,Pa 17257 WWR #05570471 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK NO. 06-7075 CIVIL TERM Plaintiff vs. DOMINIC M KNIPFING Defendant AFFIDAVIT PURSUANT TO PA R.C.P. 430 (a) BEFORE ME, a Notary Public, in and for the foregoing County and Commonwealth, personally appeared James C. Warmbrodt, 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 Defendant as being 311 Farmington Dr, Shippensburg,Pa 17257 . A true and correct copy of the Postal Service Return is marked Exhibit "2" attached hereto and made a part hereof. WWR #05570471 Finally, Affiant deposes and says that after the foregoing investigation, the exact whereabouts of the Defendant, DOMINIC M KNIPFING, is 311 Farmington Dr, Shippensburg,Pa 17257. WELTMAN, WEINBERG & REIS, CO., L.P.A. James C rmbrodt, Esquire Pa I.D. o. 2524 Welt n, inberg & Reis, Co., LLC 2718 opp s Building 436 event Avenue Pitt urg A 15219 41 -434 9 55 Sworn to and subscribed before me this CL - dday/of March, 07 71 Notary SYLVANIA OMMONW=WN&&rY public WayCity Of y County 010 My Come 29, 2 Member, Pennsylvania Association of Notaries WWR #05570471 ^ 23 - f , n t I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYL? CIVIL DIVISION DISCOVER BANK Plaintiff vs. DOMINIC M KNIPFING No. 06-7075 CIVIL TERM ORDER OF COURT MAR 16 20 01 AND NOW, to-wit, this-1 day of M 4r c.? 2007, upon c r ideration of the foregoing Motion for Service of the Complaint Pursuant to Special Order of Court and attached 1 porting affidavit, it is hereby ORDERED, ADJUDGED AND DECREED, that the service of the Compl it in Civil Action may be made on Defendant, DOMINIC M KNIPFING, by permitting the Plaintiff to mai) copy of the Complaint to the Defendant the last known address being 311 Farmington Dr , Shippensburg,Pa II 257 by Certified Mail and by Certificate of Mailing Postal Form 3817, postage prepaid. Service to be c' pleted upon mailing. BY THE COURT: WWR 405570171 W 0 ,?p SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-07075 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DISCOVER BANK VS KNIPFING DOMINIC 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 KNIPFING DOMINIC M but was unable to locate Him in his bailiwick t1nR1inT T TTTT r_ ATn'TTt1V He therefore returns the NOT FOUND , as to the within named DEFENDANT 311 FARMINGTON DRIVE KNIPFING DOMINIC M SHIPPENSBURG, PA 17257 PER OFFICE, DEFENDANT NO LONGER LIVES AT GIVEN ADDRESS. NO FORWARDING ON FILE AT POST OFFICE. Sheriff's Costs: So answers: Docketing 18.00 Service 17.60 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 1I ,? y?p Q ? 5 0 . 6 0 WELTMAN WE INBERG RE I S 12/18/2006 Sworn and Subscribed to before me this day of , A. D. le IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. DOMINIC M KNIPFING Defendant No. 06-7075 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Patrick Thomas Woodman, Esquire PA I. D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 'Jt{W R#055 7 0471 w IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 06-7075 CIVIL TERM DOMINIC M KNIPFING Defendant PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By: Patrick Thomas Woodman, Esquire PA I. D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W W R #05570471 710 c ? ? ? IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. DOMINIC M KNIPFING Defendant No. 06-7075-CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT 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. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05570471 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 06-7075-CIVIL TERM DOMINIC M KNIPFING Defendant PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James mbrodt, Esquire PA I. #42 24 WE 1'MA , WEINBERG & REIS CO., L.P.A. 27 Kop rs Building 4 Sev th Avenue P ttsb h, PA 15219 41 434-7955 WWR #05570471 C C= C-n A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. No. 06-7075-CIVIL TERM AFFIDAVIT OF SERVICE OF COMPLAINT DOMINIC M KNIPFING Defendant 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#05570471 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 06-7075-CIVIL TERM vs. DOMINIC M KNIPFING Defendant 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 Defendant, DOMINIC M KNIPFING. 1. On or about MARCH 27, 2007, 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 "1". 2. On or about FEBRUARY 08, 2008, Plaintiff mailed the complaint to DOMINIC M KNIPFING. Said certificate of mailing and certified mail receipts are attached as Exhibit "2". WELTMAN, WEINBERG & REIS, CO., L.P.A. ?r William . Moto-fan, 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#05570471 Sworn to and subscribed before me t W 1 2 day of F-C& 91 NOT ?? r MAR 18 2007ei IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVtR BANK Plaintiff VS. DOMINIC M KNIPFING No. 06-7075 CIVIL TERM ORDER OF COURT AND NOW, to-wit, this a2 7 !- day of 2007, 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 Defendant, DOMINIC M KNIPFING, by permitting the Plaintiff to mail a copy of the Complaint to the Defendant the last known address being 311 Farmington Dr, Shippensburg,Pa 17257 by Certified Mail and by Certificate of Mailing Postal Form 3817, postage prepaid. Service to be completed upon mailing. BY THE COURT: EXHIBIT J. TRUE CO FROM REWRD a Tod mo W whereof, I here ura 0 my h On ?MW of saM Court at Imo. PL PratINNNININW, #05570471 Y X.w U rt? W1 E US D PROVIDI! FdR IN3 Ra "d Fmm: 2718 444 Bldg, A36 7th Ave. 434- au plop of W&wrv MM oddtafwsd lo: uji w tk, C - O SS -XY1A-7 y 1 e .-t I HBIT a .. Yt ?° n- Ln rl For delivery information visit our website at www.usps.co OFFICIAL U-SE a . r%- Postage $ ?1`C'E n 13 Cartified Fee ! ?-. Postntatk p Return Receipt Fee p r (Endorsement Required) 2 - lJ` z M Restricted Delivery Fee r C ` (Endorsement Required) 1c rNc?do .:I- Total Postage & F... a &?Ret, o --------------------- M Apt. No or PO Box No. IBIT a _ PS Form 3800, August 2006 bee Reverse Tor,nsirucuons ._y -77 lu Of IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. DOMINIC M KNIPFING Defendant w- 'T0,75 No. s6-?9fiCIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I . D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#5570471 If V% IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 06-707-CIVIL TERM DOMINIC M KNIPFING Defendant PRAECIPE TO SETTLE. DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR Settle, Discontinue and End the above-captioned matter upon the records of the Court without prejudice to refile and mark the costs paid. WELTMAN, WEINBERG & REIS CO., L.P.A. I r .'0 2, btXm 5, /' ? By: William T. Mol an, Esquire PA I. D. #47437 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#5570471 SWORN TO AND SUBSCRIBED before me this & day of 2008 NO AR PU IC COMMONWEALTH OF PENNSYLVANIA Notarial Seal Wendy L. Gault, Notary Public City Of Pittsburgh, AIly-gheny County MY Commission Exnires ,July 15, 2010 Member, Pennsylvania Association of Notaries ?7 ^a ° r= ; ? C? ? ?h ?.:? ;^ '? tf '?' 1 ? ` -- C ? `? ?? , , > ' ? ?