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Home My WebLink About07-1974h IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: 07 1 n ?lvL c? VS. LISA M ZELTWANGER COMPLAINT IN CIVIL ACTION Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 05758410 C A Pit WLG IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No LISA M ZELTWANGER Defendant COMPLAINT AND NOTICE TO DEFEND 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 an 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 the complaint or for any other claim or relief requested by the plaintiff. You may lose money or property or other rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff, is a corporation with offices at 6500 NEW ALBANY ROAD NEW ALBANY , OH 43054 . 2. Defendant is adult individual(s) residing at the address listed below: LISA M ZELTWANGER 302 HOGESTOWN RD MECHANICSBURG, PA 17050 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011002150098549 . A copy of Plaintiff's Statement of Account s attached hereto, marked as Exhibit "A" and made a part hereof. 4. Defendant made use of said credit card and currently has a balance due and owing to Plaintiff, as of February 27, 2007 , in the amount of $7529.61 5. Defendant is in default by failing to make payments when due. 6. Plaintiff avers that the Agreement between the parties provides that Defendant will pay Plaintiff's attorneys' fees. 7. Plaintiff avers that such attorneys' fees will amount to $1000.00 r 8. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for Judgment in its favor and against Defendant , LISA M ZELTWANGER INDIVIDUALLY , in the amount of $7529.61 with interest at the legal rate of 6.000% per annum from date of judgment plus attorneys' fees of $1000.00 , and costs. James Warmbrodt,42524 WELT WEINBERG & REIS CO., L.P.A. 436 th Avenue, Suite 2718 Pit h, PA 15219 (41 ) -7955 F : 4)-3 38-7130 0 58 C A Pit WLG This law firm is a debt collector at eating to collect this debt for our client and any information obtai d will be used for that purpose. DISCO, !ER C<-RD 15 SDSN6A01 0009850 LISA ZELTWANGER 302 HOGESTOWN RD MECHANICSBURG PA New Balance Minimum Payment Due $7,729.61 $7,729.61 _ 1I Payment Due Date January 14, 2007 17050-3120 Address, e-mail or telephone change? Print change in space above, or go to Discovercard.com. Print your e-mail address to receive important Account information and special offers. Account Number 6011 0021 5009 8549 Enter Amount Enclosed Below $. Please make check payable to Discover Platinum Card. Minimum payment due includes a past due amount of $1,450.00. Consolidate bills quickly and securely with a Balance Transfer to your Discover Card - Call 1-877-353-0989 or visit Discovercard.com/balancetransfer TODAYI PO BOX 15251 111 Neil IIIII oil 11 111 1111111 WILMINGTON DE 19886-5251 11,1(1(111111111(u(u(1rIf If 1so 111111(If ,((r11(un1((11.11 000006011002150098549077296100000000772961 Discover Platinum Card Account Summary Closing Date: December 15, 2006 Account Number Payment Due Date Minimum Payment Due Credit Limit Credit Available Cash Credit Limit Cash Credit Available page 1 of 1 6011 0021 5009 8549 Previous Balance $7,729.61 January 14, 2007 Payments And Credits 0.00 $7,729.61 Purchases + 0.00 $7,000.00 Cash Advances + 0.00 $0.00 Balance Transfers + 0.00 $0.00 Finance Charges + 0.00 $0.00 New Balance = $7,729.61 Cashback Bonus® Date: April 15 1004-1k XNNew per?ir?g Cashback Bonus Balance $ 0.00 Cashback Bonus® Anniversary - - Cashback Bonus Earned + 0.00 Cashback Bonus Balance $ 0.00 Available to Redeem $ 0.00 How Can We Help You? For Account Inquiries, write to us at Discover Platinum Card, PO Box 30943 Please have your Discover Card avaEable. Soft Lake City, UT 84130 Manage your account online at Discovercard.com TDD (relecommunkations Device for the Deaf): Customer Service: 1-800-DISCOVER (1-800.347-2683) For assistance, see reverse side. Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence. Information For You Cut back on mailbox clutterl Sign up for Paperless Statements and simplify the way you manage your account. We'll send you an e-mail as soon as your statement is available online. And, while you're at Discovercard.com, you can pay your bill quickly and easily. Sign up at Discovercard.com/ps Through the generosity of our Cardmembers, Discover(R) Card has donated more than $15 million to the Make•A Wish Foundation(R). You can make a child's dream come true by electing to donate your Cashback BonUS(R) to the Make-A-Wish Foundation. To loam how, please visit Discovercord.com or visit Wish.org Finance Charge Summary Nominal Transaction Average Daily ANNUAL ANNUAL Periodic Fee Daily Periodic PERCENTAGE PERCENTAGE FINANCE FINANCE Balances Rates RATES RATES CHARGES CHARGES current billing period: 30 days Purchases $0 0.05477% 19.99% F 19.99% $0 none VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsifications to authorities, that he is Robert Adkins, (Name) Accounts Manager of Discover Financial Services, LLC., plaintiff herein, that (Title) (Company) he is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of his/her knowledge, information and belief. (Signature) WWR # 5758410 LISA M ZELTWANGER 6011002150098549 C" 71 L V ? C ra fi . - n S r Ml ` n3 -C CV) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. LISA M ZELTWANGER Defendant No.07-1974-CIVIL PRAECIPE FOR ENTRY OF JUDGMENT BY CONSENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt Paid# 42524 Weltman, Weinberg & Reis Co. 2718 Koppers Bldg 436 Seventh Avenue Pittsburgh, PA 1.5219 (412) 434-7955 WWR405758410 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. LISA M ZELTWANGER Defendant Civil Action No. 07-1974-CIVIL PRAECIPE FOR JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment against Defendant, LISA M ZELTWANGER, in the amount of $8529.61 plus costs, based upon the consent of the parties. CONSENTED TO: WELTMAN, WEINBERG & REIS CO., L.P.A., LISA M ZELTWANGER, By: Q. /w Defends I, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 07-1.974-CIVIL LISA M ZELTWANGER Defendant STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment in favor of Plaintiff and against the Defendant, LISA M ZELTWANGER, above- named, in the amount of $8529.61 pursuant to the Stipulation of the Parties for Payment and for the Entry of Judgment by Consent, as follows: Defendant admits indebtedness to Plaintiff in the amount of $7529.61 with continuing interest thereon at a rate of 6.00% per annum from MAY 9, 2007, plus attorneys' fees in the amount of $1000.00 and costs. To secure the repayment of said indebtedness, Defendant agrees that Judgment by Consent will be entered in favor of the Plaintiff and against the Defendant, LISA M ZELTWANGER, in the amount of $7529.61 plus continuing interest thereon at the rate of 6.00% per annum from MAY 9, 2007, plus attorneys' fees in the amount of $1000.00 and costs. 3. Plaintiff agrees not to Execute on its Judgment so long as Defendant causes to be delivered to Plaintiff the following payments in full by 12:00 NOON on the following dates: (a) $360.00 due by 05/20/07; (b) no less than $360.00 per month due on the 20TH day of each consecutive month thereafter until the Judgment amount plus accrued interest and costs are paid in full. 4. All payments are to be made payable to the order of "DISCOVER BANK" 5. All payments due under this agreement are to be received at the offices of Weltman, Weinberg & Reis, Co., L.P.A., 2718 Koppers Building, 436 Seventh Avenue, Pittsburgh, PA 15219. 6. In the event of default, each payment received shall be first attributed to costs, interest and then to principal. 7. Time is of the essence of this agreement and should the Defendant fail to have in the hands of Plaintiff or Plaintiff s counsel any payment in full within five (5) calendar days of the stated due date, then Plaintiff shall be immediately free to issue Execution as well as pursue all other remedies, in law or in equity, to collect the full balance of the Judgment entered hereunder plus appropriate additional interest and costs. 8. No act or omission of the Plaintiff, nor of anyone alleged to be acting on its behalf, shall constitute a waiver, estoppel, or any other excuse for non-performance of any duty undertaken by the Defendant in this Stipulation which the parties agree is final and complete. 9. Intending to be legally bound, the parties set their hands and seals thi&day of 20?. WELTMAN, WEINBERG & REIS CO., L.P.A. By: n /Y I le= James a mbrodt Paid# 425 Weltman inberg & Reis Co. 2718 K pe r Bldg 436 Se enth venue Pitts rgh, A 15219 41.2) 4-7955 58410 By: e/ /' efenda t, LISA Z,E,LT?WA?NG?E(R. IN THF. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 07-1974-CIVIL LISA M ZELTWANGER Defendant LISA M ZELTWANGER 302 HOGESTOWN RD MECHANICSBURG,PA 17050 NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Ord or Judgment was entered against you one I 1 100'1 (xx) Assumpsit Judgment in the amount of $8529.61 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession ( ) Default ( ) Verdict ( ) Arbitration ( ) Award (XX) By Consent Prothonotary By: I-C I _1,1 ;-Ilpl .2 D ? PRO H NOTARY f 6k Ewpe k WELTMAN, WEINBERG & REIS CO., L.P.A. ATTORNEYS AT LAW 2718 Koppers Building 436 Seventh Avenue Pittsburgh, Pennsylvania 15219 412.434.7955 www.weltman.com ?JG OF INNOVATION GROWTH + RESULTS May 9, 2007 LISA M ZELTWANGER 302 HOGESTOWN RD MECHANICSBURG,PA 17050 Re: DISCOVER BANK vs. LISA M ZELTWANGER Case No. 07-1974-CIVIL Our File No. 05758410 Dear LISA M ZELTWANGER: BURLINGTON, NJ 609.914.0437 CHICAGO, IL 847.940.9812 CINCINNATI, OH 513.723.2200 CLEVELAND,OH 216.685.1000 COLUMBUS, OH 614.228.7272 DETROIT, MI 248.362.6100 PHILADELPHIA, PA 215.599.1500 There is enclosed a Stipulation of the Parties for Settlement and for the Entry of Judgment by Consent. You should see that the enclosed Stipulation is signed and returned to our office in the enclosed self-addressed, stamped envelope along with your first payment, on or before 05/20/07. Upon receipt of the signed Stipulation and your first payment, I will sign the Stipulation and forward it to the Court for filing. Should you have any questions. or comments, please feel free to contact me. Thank you for your cooperation in this matter. Ve S -(? WARMBRODT, ESQUIRE JCW:cxc Enclosures THIS LAW FIRM IS ATTEMPTING TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. W P+ ti Y 0 c ?:33 ?-C r.a L.+J 0 "R r i "t l?[R --C SHERIFF'S RETURN - REGULAR CASE NO: 2007-01974 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS ZELTWANGER LISA M 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 ZELTWANGER LISA M the DEFENDANT , at 1650:00 HOURS, on the 23rd day of April 2007 at 302 HOGESTOWN ROAD MECHANICSBURG, PA 17050 by handing to PETER EDWARDS, HUSBAND 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: So Answers: Docketing 18.00 Service 10.56 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 S'.?3'?? (? -38.56 04/24/2007 WELTMAN WEINBERG REIS Sworn and Subscibed to By: 7z,-,-, /,,1 before me this day of , A.D. DepuXI Sh?r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. LISA M ZELTWANGER Defendant No. 07-1974-CIVIL PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA. I. D.#47437 WELTMAN, WEINBERG & REIS CO 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05758410 L.P.A. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 07-1974-CIVIL LISA M ZELTWANGER Defendant PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WELTMAN, WEINBERG & REIS CO., L.P.A. By: ?,?` William T. Molcz n, quire PA. I.D.#47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #05758410 Sworn to and subscribed before me this ? day of Sgptember, AR^BLIC COMMONWEA01A it r'LN a+q Notarial Seal Wayne A. Jones, Notary Public City of Pittsburgh, Allegheny County My Commission Expig;s June 29, 2010 Member, Pennsylvania Association of Notaries FILED '"- "k? ''F- OF T HE 2099 OCT 13 FM 2: 13 ?S.oa??A?JY e?? BgiB?a a? a3??r