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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