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Home My WebLink About03-0645 ATTORNEy: ACCOUNT NUMBER: BALANCE: CARDMEMBER (S): STATE OF OHIO COUNTy OF FRANKLIN BERMAN 6011002250645330 $4763.09 REBEKAHMLEIBY K. Ray, 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 servmmg 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 Plaintiff'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 the Discover Card Account 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 Disc. over Bank on the account, and exhibit A is a copy of the Cardmember Agreement between Discover Bank .a~.c~ the above re~erenc, ed Debtor(s). The Cardmember Agreement governs, the te. rms and condmons of the relationship between connection w~th the account. Discover Bank and t~-~ r,_L .... "~ ~emor(s) in 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 aresident of the State and of the COuntry in which this action has been filed. I declare under penalty o£ perjury that the foregoing is true and correct to the best of my knowledge. Sworn and Subscribed before me, This day of Tuesday, June 11, 2002. DORIS WALKER ALLEN Notary Pul~ic In and for the State of O~io My Commissioa Expires Feb. 15, 2005 SHERIFF'S RETURN - REGULAR CASE NO: 2003-00645 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS LEIBY REBEKAH M HAROLD WEARY , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LEIBY REBAKAH M the DEFENDANT at 431 BRIDGE STREET NEW CUMBERLAND, PA 17070 , at 1727:00 HOURS, on the 14th day of February , 2003 APT 3S by handing to BEBEKAH LEIBY a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 11.73 Affidavit .00 Surcharge 10.00 .00 39.73 Sworn and Subscribed to before me this '? ~ day of ~ ~ A.D. /P~o~honotary So Answers: R. Thomas Kline Y ~ 02/19/2003 ERIC BERMAN Deputy ~eriff Our File No. 165775 ATTORNEYS FOR PLAINTIFF ERIC M. BERMAN, PoC. 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 REBEKAH M LEIBY DISCOVER BANK c/o ERIC M. BERMAN, P.C. 985 Old Eagle School Road, Suite 505 : Wayne, PA 19087 : : TRIAL DIVISION CIVIL ACTION No. 03-645-CIVIL TEAM PRAECIPE TO ENTER DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter a default judgment in favor of Plaintiff, DISCOVER BANK , and against Defendant, REBEKAH M LEIBY for failure to answer or otherwise respond to the Complaint - Civil Action. The Complaint was served upon Defendant on 02/14/2003, 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 ~ l{~l0 is attached hereto as Exhibit B. 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 $4,763.09, being the amount demanded in the Complaint, together with attorneys fees and court costs. ERIC M. BERMAN, P.Co Attorneys for Plaintiff By: Eric Mo Berman, Esquire ERIC M. BERMAN, P.C. Attorneys for Plaintiff By: Ron Z. Opher, Esquire SPACEJUD-ZF Our File No. 165775 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 VS. REBEKAH M LEIBY DISCOVER BANK c/o ERIC M. BERMAN, P.Co - 985 Old Eagle School Road, Suite 505 : Wayne, PA 19087 : TO: REBEKAH M LEIBY 431 BRIDGE ST APT 3S NEW CUMBERLND, PA 17070-1929 COURT OF COMMON PLEAS COUNTY OF CUMBERLAND TRIAL DIVISION CIVIL ACTION No. 03-645-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 Our File Nc.,_ , ~-,,'~v~ TOE ..... ~'~"'~ ~- }~ /,f~:,"~ i"~ Berman, Esquire, I.D. ,-, ~<ar -, Opher Esquire, I.D. 57507 , '. (;1,~ Eagle c ~ ,.,c hooi Road, ~%;"rL~t, PA 19087 Di' SCOVER BANK : c/c; ERIC M. BERI~AN, P.C. : 985 Old Eagle School Road, Suite 505 : Wayne, PA 19087 . VS. REBEKAH M LEIBY : CC)JRT OF COMMON PLEAS CCUNTY OF (-,[MBERLAND TRIAL I)IVI =,ION CIVIL ACTION No. 03-645-CIVIL TEAM NOTIGE OF INTENTION TO TAKE DEFAULT JUDGMENT TO- REBEF~H M LE IBY NEW CU.BERLN , PA OAT . OF NOTiCe: /1%io3 IMPORTANT N(_TICE You are in default because yo.~l have failed 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 Judgment may be entered against you without a Hearing, and you may lose your property or other important rights. YOU SHOULD TAKE THIS NOTIZE ~0 YOUR--LAWYER AT ONCE. IF YOU I3D NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW OR FIND OUT WHERE YOU CAN GET LEGAL HEIA0. LAWYER REFERRAL SERVICE, C;OUNTY OF CUMBERLAND COUNTY BAR ASSOC:IATION Address- 2 LIBERTY AVE., CARLISLE, PA 17013 Tel.: 800-990-9105 LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATEMENTE. SI NO TIENE ABOGA O SO NO TIENE EL DINERO SUFICIENTE DE,PAGAR TA~ ~vIClO. VAYA EN PERSONA 0 LLAME POR TELEFONO A LA OFI£,INA CUYA~I~I~N SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR IXDNDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. LAWYER REFERRAL SERVICE, COUNTY OF CUMBERLAND BAR ASSOCIATION Address: 2 LIBERTY AVE. CARLISLE, PA ].7312~ Tel :~00-990-9108 SPACEJUD-ZF ,. ~, ERIC M. BERMAN, p.C. ERIC M. BERMAN, P.C. Attorneys for Plaintiff Attorneys for Plaintiff' By: Eric M. Berman, Esquire By: Ron Z. Opher, Esquire Our File No. 165775 ATTORNEYS FOR PLAINTIFF ERIC M. BERMAN, P.C. BY: Eric M. Berman, Esquire, IoI). 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 ERIC M. BERMAN, P.C. : 985 Old Eagle School Road, Suite 505 - Wayne, PA 19087 - VS. REBEKAH M LEIBY COURT OF COMMON PLEAS COUNTY OF CUMBERLAND TRIAL DIVISION CIVIL ACTION No. 03-645-CIVIL TEAM CERTIFICATION OF ADDRESSES TO THE PROTHONOTARY- The address of the Plaintiff, Judgment Creditor, is c/o Eric M. Berman, P.C., 985 Old Eagle School Road, Suite 505 Wayne, PA 19087. ' ~]e last known address of the Defendant, Judgment Debtor, is 431 BRIDGE ST APT 3S, , NEW CUMBERLND, PA 17070 1929. Eric M. 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 F~eNo. 165775 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: 431 Bridge St. Apt 3S, New Cumberland, PA 17070 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 my knowledge, information and belief, and I understand that the statemems in said certification and affidavit are made subject to the penalties of 18 Pa.C.S. 4904 relating to unswom falsification to authorities Dated: March 14, 2003 Ron Z. Opher, Esq. Attorney for the Plaintiff