IN THE COURT OF COMMON PLEAS

ALLEGHENY COUNTY

COMDOC ) CASE. NO. GD08-025292

3458 MASSILLON ROAD )
UNIONTOWN, OH 44685 ) JUDGE: R. Stanton Wettick
)
Plaintiff )
v. )
)
)
KAREN M. DERZACK ) Answer to Weltman,
127 WINDWOOD DRIVE ) Weinberg and Reis
WEXFORD, PA 15090 ) Response to Defendant’s
) Motion for Reconsideration
Defendant

NOW COMES the Defendant, Karen Derzack, pro se, and respectfully presents this

Answer to Weltman, Weinberg and Reis Response to Defendant’s Motion for Reconsideration.

The basis for the Answer is set forth as follows:

1. Weltman, Weinberg and Reis purports that, despite the fact that the Honorable R. Stanton

Wettick clearly stated that they were to provide documentation at the hearing, they do not have

to comply because it was not actually written in the order.

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2. The Court’s decision to vacate the January 9, 2009 and July 9, 2010 court orders in these

proceedings clouds the issue surrounding the initial foreign judgment of November 25, 2008.

Plaintiff failed to appear, and in accordance with the Uniform Enforcement of Foreign Judgment

Act (42 Pa C.S.A. § 4306), the merit of defendant’s appeal from the foreign judgment would

have granted the motion to strike foreign judgment. A claim that the Plaintiff was not given

proper notice is false, as the Plaintiff terminated its’ relationship Weltman, Weinberg and Reis,

and Weltman, Weinberg and Reis did in fact withdraw from the case.

3. Defendant did not voluntarily appear in Ohio, and defendant presented to the Ohio Court a

consistent objection to jurisdiction, which invalidates the efficacy of a foreign judgment in

accordance with 69:37, Standard Pennsylvania practice 2d.

4. Plaintiff terminated its relationship with Weltman, Weinberg and Reis in this matter, and

Weltman, Weinberg and Reis has never presented the Court with any notice to enter an

appearance. Accordingly, they cannot represent plaintiff in this matter without entering a notice

of appearance, and any action brought about by Weltman, Weinberg and Reis in this matter

should be stricken as they no longer represent the Plaintiff.

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 WHEREFORE, Defendant, Karen Derzack, Pro Se, respectfully requests that this

Honorable Court reconsider its’ Order of Court, and grant defendants’ Motion to Strike Foreign Judgment

and issue an Order that also vacates the November 25, 2008 Order with Prejudice.

Respectfully submitted,

__________________________

KAREN M. DERZACK
127 Windwood Drive
Wexford, PA 15090
Telephone: (724) 766-4070

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 IN THE COURT OF COMMON PLEAS
ALLEGHENY COUNTY

COMDOC ) CASE. NO. GD08-025292

3458 MASSILLON ROAD )
UNIONTOWN, OH 44685 ) JUDGE: R. Stanton Wettick
)
Plaintiff )
v. )
)
)
KAREN M. DERZACK ) Answer to Weltman,
127 WINDWOOD DRIVE ) Weinberg and Reis
WEXFORD, PA 15090 ) Response to Defendant’s
) Motion for Reconsideration
Defendant

CERTIFICATE OF SERVICE

I hereby certify that I served a true and correct copy of the within Answer to Weltman,
Weinberg and Reis Response to Defendant’s Motion for Reconsideration to the person(s) listed
below by regular United States Mail, Postage Prepaid, on the date indicated.

ComDoc
3458 Massillon Road
Uniontown, OH 44685

_________________________

October 4, 2010 Karen M. Derzack, PRO SE

 Karen M. Derzack
127 Windwood Drive
Wexford, PA 15090

October 4, 2010

Judge R. Stanton Wettick, Jr.

Court of Common Pleas
Allegheny County
818 City County Building
Pittsburgh, PA 15219

RE: Case # GD08-025292

Dear Judge Wettick:

Please find enclosed a Answer to Weltman, Weinberg and Reis Response to Defendant’s
Motion for Reconsideration to the abovementioned case. A copy has been sent to the Clerk of
Courts as well as plaintiff.

Sincerely,

Karen M. Derzack
 Karen M. Derzack
127 Windwood Drive
Wexford, PA 15090

October 4, 2010

Department of Court Records

City County Building – First Floor
414 Grant Street
Pittsburgh, PA 15219

RE: Case # GD08-025292

Please file the enclosed Answer to Weltman, Weinberg and Reis Response to Defendant’s
Motion for Reconsideration to the abovementioned case. Thank you.

Sincerely,

Karen M. Derzack