HomeMy WebLinkAbout03-0643
ATT( ~ ~.NEY:
ACC{ t !NT NUMBER:
BAL.; gCE:
CAll; '; ! EMBER (S):
BERMAN
60110026606N(~908
$4532.7 l
TITO TEl'
STA, , OF OHIO
COl. ,'ih: OF FRANKLIN
K. R:~, personally appeared before me, finis day and after being duly sworn, according to law,
upon !: :+her oath and says:
I am ~ :~cgal Placement Account Manager tbr DISCOVER FINANCIAL SERVICES INC., the
servk i, ~,,, agent of DISCOVER BANK, an FDIC insured Delaware State Bank.
THA his affidavit is made on the basis of m,, personal knowledge and in support of PlaintifFs
suit ~ .ccount against theDebtor(s)
THA m my capacity as Legal Placement Account Manager, I have control over and access to
record: ;'egarding the Discover Card Accounl oF the above referenced Debtor(s), further, that I
have i'.~'sonally inspected said Account and statements regarding the balance due on said account.
DIS(', V'ER FINANCIAL SERVICES, INC. maintains these records in the ordinary course of
busi~. ,.
THA~: tile annexed statement of account :s a i,'ue and correct statement of what is now due and
owini., )iscover Bank on the account, at~d exhibit A is a copy of the Cardmember Agreement
betw,:~ , Discover Bank and the above tctc:,.'nced Debtor(s). The Cardmember Agreement
govc-t thc ten:as and conditions of the rck~t~<~ ship between Discover Bank and the Debtor(s) in
conn .~ on with the account.
Basc~i ~ my review of the account records, t~> the best of my knowledge and belief the above
refer. ,cd Debtor(s) is not engaged in thc an ii:~ary service of the United States and is aresident
of tN 'ate and of the Country in which this ac/ion has been filed.
I de~: :,: under penalty of pmjury that ,~!:,~ :i~regoing is tree and correct to the best of my
knox~i ~ige.
Swo, ~ ~d Subscribed before me,
This ~, , or'Wednesday, July 10, 2002.
j.~ No=~ Public
. In and for the State of Ohio
~ My Commission Expires
~.~~~ ~"ff Apr. 05, 2006
"',,~- O~ ~
SHERIFF'S RETURN - REGULAR
CASE NO: 2003-00643 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DISCOVER BANK
VS
TEP TITO
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
TEP TITO the
DEFENDANT ,
at 1859:00 HOURS, on the 19th day of February , 2003
at 3627 LISBURN ROAD
MECHANICSBURG, PA 17055
by handing to
TITO TEP
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
Service
Affidavit
Surcharge
18 00
9 66
00
10 00
00
37 66
Sworn and Subscribed to before
me this ~- day of
~ ~3 A.D.
honota~ ~ ' ~
So Answers:
R. Thomas Kline
02/20/2003 ~
ERIC BERMAN
By: ~
Deputy Sheriff
Our File No. 166921
ATTORNEYS FOR PLAINTIFF
ERIC M. BERMAN, P.C.
BY: Eric M. Berman, 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
~X
COURT OF COMMON PLEAS
COUNTY OF CUMBERLAND
DISCOVER BANK
c/o ERIC M. BERMAN, P.C. '
985 Old Eagle School Road, Suite 505 '
Wayne, PA 19087 '
o
TITO TEP
TRIAL DIVISION
CIVIL ACTION
No. 03-643 CIVIL TEAM
PRAECIPE TO ENTER DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Please enter a default judgment in favor of Plaintiff,
DISCOVER BANK
and against Defendant, TITO TEP ,
for failure to answer or otherwise respond to the Complaint - Civil
Action.
The Complaint was served upon Defendant on 02/19/2003,
by the Sheriff's Office of COUNTY OF CUMBERLAND County.
A copy of the Notice of Intention to Take Default served upon
the Defendant by regular mail on
is attached hereto as Exhibit
I certify that written notice of the intention to file this pracipe
was mailed or delivered to the party against whom judgment is to be
entered after the default occurred and at least ten days prior to
the date of the filing of this praecipe. Copies are attached. R.C.P.237.1.
Assess damages in the principal amount of $4,532.71, being
the amount demanded in the Complaint, together with attorneys fees
and court costs.
ERIC M. BERMAN, P.C.
Attorneys for Plaintiff
By: Eric M. Berman, Esquire
ERIC M. BERMAN, P.C.
Attorneys for Plaintiff
By: Ron Z. Opher, Esquire
SPACEJUD-ZF
Our File No. 166921
ATTORNEYS FOR PLAINTIFF
ERIC Mo BERMAN, P.C.
By: Eric M. Berman, Esquire, I.I). 83698
By: Ron Z. Opher, Esquire, I.D. 57507
985 Old Eagle School Road, Suite 505
Wayne, PA 19087
(610) 902-0530
X
DISCOVER BANK
c/o ERIC M. BERMAN, P.C. '
985 Old Eagle School Road, Suite 505 '
Wayne, PA 19087 '
VS.
TITO TEP
TO:
TITO TEP
3627 LISBURN RD
MECHANICSBURG, PA
17055-6710
COURT OF COMMON PLEAS
COUNTY OF CUMBERLAND
TRIAL DIVISION
CIVIL ACTION
No. 03-643 CIVIL TEAM
NOTICE
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are
hereby notified that a JUDGMENT BY DEFAULT has been entered
against you in the above proceeding and that enclosed herewith is a
copy of all the (record) documents filed in support of the said
Judgment.
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL-
ERIC M. BERMAN, P.C., Attorneys at Law.
Attention: Eric M. Berman, Esquire, or Ron Z. Opher, Esquire, at
this telephone number. 1-610-902-0530. ~ ~.
PROTHONOTARY
~ ' ~'*' '5 ); Z. Of:d:,':: - [~squire, I.D. 5750?
Ua ~,-n~~ 5 A ] 9( ~"}
D!SCOVEF BANK
c,'o EP. iC M. BERBAli, P.C. :
9[;5 Old Eagle School Road, Suite 505 :
Wayne, PA ].9087 :
TiTO TEP
X
COURT OF COMMON PLEAS
COUNTY OF CUMBERLAND
TRIAL DIVISION
CIVIL ACTION
No. 33-~,4d CIVIL TEAM
NOTICE (DF INTENTION TO TAKE DEFAULT JUi~]MENT
TO: TITO TEP
'~[627 LISBURN RD
MECHAN I CSB[[ R(= PA 17055-6710
DATE OF NCTIOE:
IMPORTANT N~_ TIt, E
You are in default because you have fai2ed to take action
required of you in this case. Unless you act within ten (10) days
of the date of this Notice, as set forth above, a Jud~nent may be
entered against you without a Hearing, and you may lose your
property or other important rights.
c · DNCE IF YOU
YOU SHOULD TAKE THIS NDTICE TO YOUR LA~fER AT c · .
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE
OFFI£,E SET FORTH BELOW OR FIND OUT WHERE YOU CAN GET LEGAL HELP.
LAWYER REFERRAL SERVICE, COUNTY OF CUMBERLAND COUNTY BAR ASSOCIATION
Address: 2 LIBERTY AVE., CARLISLE, PA 17013 Tel.: 800-990-9!08
LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATEMENTE~--, SI NO TI~NE .gi~),GA
0 SO NO TIENE EL DINERO SUFICIENTE DE PAGAR Ta%~SER~tCIO. /< VA~ir~ EN~~
PERSONA 0 LLAME POR TELEFONO A LA OFICINA CUY~-~~3N SE ENCUE.N3~A
ESCRITA ABAJO PARA AVERIGUAR I~NDE SE PUEDEf'.~ONSEGUIR~ . ASISTENCIA LEGAL.
LAWYER REFERRAL SERVICE, COUNTY OF CUMBERLANI) BAR ASSOCIATION
Address: 2 LIBERTY AVE., CARLISLE, PA 17013 Tel.: 800-990-9108
SPACEJUD-ZF
ERIC M. BER/MAN, P.C. ERIC M. BEY~AN, P.C.
Attorneys for Plaintiff Attorneys for Plaintiff
By: Eric M. Berman, Esquire By: Run Z. Opher, Esquire
Our File No. 166921
ATTORNEYS FOR PLAINTIFF
ERIC M. BERMAN, P.C.
BY: Eric M. Berman, Esquire, IoD. 83698
BY: Ron Z. Opher, Esquire, I.D. 57507
985 Old Eagle School Road, Suite 505
Wayne, PA 19087
(610) 902-0530
X
VSo
TITO TEP
DISCOVER BANK
c/o ERIC M. BERMAN, P.C. -
985 Old Eagle School Road, Suite 505 -
Wayne, PA 19087 -
COURT OF COMMON PLEAS
COUNTY OF CUMBERLAND
TRIAL DIVISION
CIVIL ACTION
No. 03-643 CIVIL TEAM
CERTIFICATION OF ADDRESSES
TO THE PROTHONOTARY:
The address of the Plaintiff, Judgment Creditor, is c/o
Eric M. Berman, P.Co, 985 Old Eagle School Road, Suite 505,
Wayne, PA 19087.
The last known address of the Defendant, Judgment Debtor, is
3627 LISBURN RD, , MECHANICSBURG, PA 17055 6710.
Eric Mo Berman, P.C.
Attorneys for Plaintiff
By: Eric M. Berman, Esquire
SPACEJUD-zf
Eric M. Berman, P.C.
Attorneys for Plaintiff
By: Ron Z. Opher, Esquire
File No. 166921
AFFIDAVIT OF NON-MII.ITARY SERVICE
Commonwealth of Pennsylvania:
SS.
County of Cumberland
I, Ron Z. Opher, Esq. being duly sworn according to law, depose and say that I represents the
Plaintiff[s) in the above entitled case; that I is authorized to make this affidavit on behalf of the
Plaintiff[s): and that the above named Defendant(s) is (are) above 18 years of age; the address of
Defendant(s) is:
3627 Lisburn Rd., Mechanicsburg, PA 17055
Occupation of Defendant(s) is unknown; and Defendant is not in the Military Service of the United
States, nor any State or Territory thereof or its allies as defined in the Soldiers' and Sailors' Civil
Relief Act of 1940 and the amendments thereto.
I, Ron Z. Opher, Esq.,verify that the statements made in the foregoing certification and affidavit
are true and correct to the best of myknowledge, information and belief, and I understand that the
statements in said certification and affidavit are made subject to the penalties of 18 Pa.C.S. 4904
relating to unsworn falsification to authorities
Dated: March 14, 2003
Ron Z. Opher, Esq.
Attorney for the Plaintiff