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Home My WebLink About02-5790Our File No. 154792 ATTORNEYS FOR PLAINTIFF ]~RIC M. BERMAN, P.C- BY: Eric M. Barman, Esquire, I.D. 83698 BY: Ron Z. Opher, Esquire, I.D. 57507 985 Old Eagle School Road, Suite 505 Wayne, PA 19087 (610) 902-0530 DISCOVER BANK c/o ERIE', M. BERMAN, P.E;. : oulte : 985 Old Eagle School Road, '~ ' 505 Wayne, PA 19057 : HARRY L ,~AMPoON COURT OF COMMON PLEAS COUNTY OF CUMBERLAND TRIAL DIVI =,ION CIVIL ACTION Term NOTICE 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 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 this complaint or for any other claim or relief required by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT (.NGE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE ,SET FORTH BELOW OR FIND ()UT WHERE YOU CAN GET LEGAL HELP. AVISO Le hen demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginam sig~ientes, usted tiene veinte (20) dias de plaza al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o en persona o con un abagado y entregar a la corte en forma esorita sus defenses o sus objeciones a las demandas en contra de su persona. Sea avisado eue si usted no se defiende, la corte tomara medidas y puede continuer la demanda en contra suya sin previo aviso o notificacion. A dames la la corte puede decidir a favor del demandante y requiere qua usted compla con redes las provisiones de esta demanda. Usted puede perder dinero o sus propiededes u otros derechos i~ortantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATEMENTE. SI NO TIENE ABOGA O SO NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERiGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. LAWYER REFERRAL ,~ERVI.~E~ (~OUNTY (IF COMBERLAND BAR ASSOCIATION Address: 2 LIBERTY AVE., CARLISLE, PA 17(1113 Tel.: 800-990-9108 Our File No. 154792 ATTORNEYS FOR PLAINTIFF ERIC M. BERMAN, P.C. BY: Eric M. Berman, Esquire, I.D. 83698 BY: Ron Z. Opher, Esquire, I.D. 57505 985 Old Eagle School Road, Suite 505 Wayne, PA 19087 (610) 902-0530 DISCOVER BANK c/o ERIC', M. BERMAN, P.C. : 985 Old Eagle School Road, Suite 505 : Wayne, PA 19087 : HARRY L SAMPSON COMPLAINT C. 0URT OF COMMON PLEAS COUNTY OF CUMBERLAND CIVIL ACTION Term 1. Plaintiff, DISCOVER BANK , is a DELAWARE BANK licensed to do business in the Conm~onwealth of Pennsylvania with place of business at P.O. BOX 800c~, HILLIARD, OH 4o0~. its 2. The Defendant (s), HARRY L SAMPSON , resides at 207 CHESTNUT ST , MT HOLLY SPGS, PA 17065-1~11. 3. There is due from the Defendant(s) the sum of $3,954.44 for credit extended by Plaintiff to Defendant(s), acct. no. 6011002398534438, and which such credit was drawn and used by the Defendant(s). Defendant(s) is in default for failure to make payments for such use. 4. The Plaintiff has lnade demand upon the Defendant(s) for payment of monies in the sum of $3,954.44 advanced to Defendant(s) through Defendant(s) use of the above-referenced credit account,, but Defendant(s) has failed and refused to pay the said sum or any part thereof. 5. All applieable credits, if any, have been duly applied to Defendant(s) credit account. WHEREFORE, Plaintiff claims of the Defendant(s) the sum of $3,954.44 plus interest, attorneys fees and costs which are justly due and owing from the Defendant(s) to the Plaintiff. Dated: MAY 07, 2002 SPACE-AQ By:ERIt' ERIC M. BERMAN, ESQUIRE BY' RON Z. .PHER, Esquire Attorneys for Plaintiff VERIFICATION RON Z. OPHER, ESQUIRE, being duly sworn according to law, deposes and says that he is of Counsel to the Law Firm of Eric M. Berman, P.C., and/or ERIC M. BERMAN, ESQUIRE, being duly sworn according to law, deposes and says that he is the Principal attorney of Eric Berman, P.C., attorneys for the Plaintiff, and as said attorney, he is authorized to take this verification on its behalf, and that the facts in the Complaint as set forth therein are true and correct to the best of }his knowledge, information and belief. I verify that the statements made in the within instrument are true and correct. I understand that false statements are subject to the penalties of 18 Pa C.S.A. Section 4904 relating to unsworn falsifications to authorities. ERIC Mo BERMAN, ESQUIRE Dated: MAY 07, 2002 RON Z. OPHER, ESQUIRE SPACE-AQ ATTORNEY: ACCOUNT NUMBER: BALANCE: CARDMEMBER (S): BERMAN 6011002398534438 $3954.44 HARRY L SAMPSON STATE OF OHIO COUNTY OF FRANKLIN K. Lanning, personally appeared before me, this day and after being duly sworn, according to law, upon his/her oath and says: I am a Legal Placement Account Manager for DISCOVER FINANCIAL SERVICES INC., the servicing agent of DISCOVER BANK, an FDIC insured Delaware State Bank. THAT this affidavit is made on the basis of my personal knowledge and in support of Plaintif±'s suit on account against the Debtor(s) THAT, in my capacity as Legal Placement Account Manager, I have control over and access to records regarding Discover Card Account 6011002398534438 of the above referenced Debtor(s), further, that I have personally inspected said Account and statements regarding the balance due on said account. DISCOVER FiNANCIAL SERVICES, iNC. maintains these records in the ordinary course of business. THAT the annexed statement of account is a true and correct statement of what is now due and owing Discover Bank on the account, and exhibit A is a copy of the Cardmember Agreement between Discover Bank and the above referenced Debtor(s). The Cardmember Agreement governs the terms and conditions of the relationship between Discover Bank and the Debtor(s) in connection with the account. Based on my review of the account records, to the best of my knowledge and belief the above referenced Debtor(s) is not engaged in the military service of the United States and is a resident of the State and of the Country in which this action has been filed. I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. Affiant Sworn and Subscribed before me, This day of Monday, November 12, 2001. I ~ KAREN RENEE LIVENGOOD ~ = Notary Public * ~ In and for the State of Ohio ~ My Commission Expires ~'~ Apr. 05, 2006 SHERIFF'S RETURN - REGULAR CASE NO: 2002-05790 p COMMONHEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS SAMPSON HARRY L KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SAMPSON HARRY Lthe DEFENDANT , at 1345:00 HOURS, on the 13th day of December , 2002 at 207 CHESTNUT ST MT HOLLY SPRINGS, PA 17065-1211 by handing to HARVEY SAMPSON, BROTHER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff,s Costs: Docketing 18.00 Service 4.14 Affidavit .00 Surcharge 10.00 .00 32.14 Sworn and Subscribed to before me this ~,-~ day of f ! ~rothonotary So Answers: R. Thomas Kline 1211712002 ERIC BERMAN By: