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Home My WebLink About07-2159IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: D~f _al~ `lu~~ l vs. ~~ COMPLAINT IN CIVIL ACTION SHARON L BOOKAMIRE 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 05813444 C A Pit WLG a IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No SHARON L BOOKAMIRE 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 individuals? residing at the address listed below: SHARON L BOOKAMIRE 124 2ND ST ENOLA, PA 170.25 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011002590717534 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 March 28, 2007 in the amount of $8871.57 . 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 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 SHARON L BOOKAMIRE ,INDIVIDUALLY in the amount of $8871.57 with interest at the legal rate of 6.000% per annum from date of judgment plus attorneys' fees of $1000.00 and costs. James WELTM 436 Pitt (41 ) 0 warmbrod.t,42524 WEINBERG & REIS CO., L.P.A. ve th Avenue, Suite 2718 bu gh, PA 15219 34-7955 12-338-7130 444 C A Pit WLG This law firm is a debt collector atpting to collect this debt for our client and any information obtai ed will be used for that purpose. pIS,C~/ER New Balance Minimum Payment Due , Account Number 6011 0025 9071 7534 $8,871.57 $8,871.57 Enter Amount Enclosed Below 15 SDSNfiA01 0007009 SHARON BOOKAMIRE 124 2ND ST ENOLA PA 17025-3203 Please make check payable to Discover Platinum Card. Minimum payment due includes a post due amount of 51 857.00.~~ P Save time an`~ a stamp this mo~ith by paying your bill online. To find out about our free and flexible online payment features, visit Discovercard.com/payments PO BOX 15251 ~~~~~~~~~~~~'~~~~~~~~~~~~~~ WILMINGTON DE 19886-5251 ~ur~~~r~u~u~~~n~u~~ur~r~n~~~~~~i~un~~~~~~nu~~~r~n~ Payment Due Date February 14, 2007 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 aed special ofFers. Account Number :Payment Due Date 'Minimum Payment Due Credit Limit Credit Available ;Cash Credit limit -Cash Credit Available 60110025 9071 7534 February 14, 2007 $8,871.57 56,000.00 so.oo 50.00 50.00 page 1 of 1 Previous Bokurce $8,871.57 Payments And Credits - 0.00 Purchases + 0.00 Cash Advances + .0.00 Balance TransFers + 0.00 Finance Charges + 0.00 New Bakurce = 58,871.57 CaShback Bonus® Opening Cashback Bonus Balance S 0.00 New Cashback Bonus Eamed + 0.00 Cashbadc Bonus Balance 5 0.00 CashbackBonus®Annivenary __....--------- ----. --Availablefo~Redeam_----. -----------.--5_.__--_O.OII-- -- Date: September 15 How Can We Hel You? For Account Inquiries, wrde,e us at. p Please have your Discover card ava~labls. Discover Pkatinum Card, PO Box 30943 soh lake city, UT 8.4130 tNanage your aaourM online at Discavercard.com TDD (ishxorrwssnications Device for the DsaFl: ~Custornsr Service: 1-800-DISCOVER (1-800-347-2683) For assistance, see reverse side. ~Transaetions $0 Fraud Liability Guarantee Use your Discover Card with confidence. :Information For You Cut back on mailbox clutter! 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 Discovercord.com/ps ;Through the generosity of our Cardmembers, Discover(R) Card has donated more HranC~~i~~ ke-A-Wish ;Foundation(R~. You can moke a child's dream come true by electing to donate your rlo he ;Make-A-Wish Foundation. To Isom how, please visit Discovercard.com or visit Wish.org_ _ ~ _ ;Finance Charge Summary . Nominal Transaction Average Daily ANNUAL ANNUAL Periodic fee Daily Periodic PBK3:NTAGE PERCEPRAt~ FRdMICE FINANCE nces Rates RATES RATES CF~ARGES CF~ARGES 00000601100259071753408871570000000D887157 Discover Platinum Card Account Summary Cbsing Date: Jartuary 15, 2007 ;current billing period: 31 days 'Purchases 50 0.07121% 25.99% V 25.99% SO none ,Cash Advances 50 0.07121 % 25.99% V 25.99% 50 50 .___... _.._ L:11:.__ ___.__I. 1 C J__ 1 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 # 5813444 SHARON L BOOKAMIRE 6011002590717534 ti 1 R~ e G -~` c-~ c.' .~ + c. :. `. r--.. Wit;, <r.~ ._., -;, -..l N c~~ sip; ---, _, .~ ~~~~ =~~' ;x7 -C SHERIFF'S RETURN - REGULAR CASE NO: 2007-02159 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS BOOKAMIRE SHARON L VALERIE WEARY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BOOAMIRE SHARON L the DEFENDANT at 1834:00 HOURS, on the 27th day of April 2007 at 124 2ND STREET ENOLA, PA 17025 SHARON L BOOKMTRE by handing to 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 14.40 Affidavit .00 Surcharge 10.00 .00 dJ~K(o 9 ~ ~2 . 4 0 Sworn and Subscibed to before me this day So Answers: .a~ R. Th as Kline 04/30/2007 WELTMAN WEINBERG & REIS By : /~ Deputy S eriff of A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. SHARON L BOOKAMIRE Defendant No. 07-2159-CIVIL PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOLCZAN, ESQUIRE PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05813444 Judgment Amount $ 9871..57 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. M IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. SHARON L BOOKAMIRE Defendant TO THE PROTHONOTARY: Civil Action No. 07-2159-CNIL PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, SHARON L BOOKAMIRE above named, in the default of an Answer, in the amount of $9871.57 computed as follows: Amount claimed in Complaint $8871.57 Interest from date of judgment at the legal interest rate of 6% per annum Attorney's fees $1000.00 TOTAL $9871.57 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By: ~. WILL T, MOLCZAN, ESQUIRE PA LD.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#05813444 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7"' Avenue, Pittsburgh, PA ] 521.9 And that the last known address of the Defendant is: 124 2ND ST ENOLA,PA 17025 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 07-2159-CIVIL SHARON L BOOKAMIRE Defendant NOTICE OF JUDGMENT OR ORDER TO: ( )Plaintiff (xx) Defendant ( )Garnishee You are hereby notified that the following Order or J dgment was entered against you on ~,pOT (xx) Assumpsit Judgment in the amount of $9871.57 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 (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: PROT NOTARY EPU ) SI-iARON L BOOKAMIRE 1.24 2ND ST ENOLA,PA 1.7025 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`~' Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK ,.-q ~^. Plaintiff Case # ~ ~~ l ~1.~ ~''~~ SHARON L BOOKAMIRE Defendant(s) IMPORTANT NOTICE TO: SHARON L BOOKAMIRE 124 2ND ST ENOLA,PA 17025 Date of Notice: WWR#: 05813444 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING OFFICE 5ET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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 PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 4 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER. BANK Plaintiff vs. SHARON L BOOKAMI:RE Defendant Case no: 07-21.59-CIVIL NON-MILITARY AFFIDAVIT The undersigned, who first being duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. § 521.. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, SHARON L BOOKAMIRE is not in the military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the Defendant, SHARON L BOOKAMIRE is not in the military service. Further Affiant sayeth naught. AFFIANT SWORN TO AND SUBSCRIBED in my presence this ~a day of T r~ . ~. COMMONWEAL?r1 !"~~ ='r i`~~<~YLV't'1~cGA ~ Notts _ _ - NO RY ~PUBL[ Wayne A.,lon~~: ~, `°~~aryPublic City Of Pittsburgh. t~ii~~eny County My Commission E~irk> ,tune 29, 2010 Member, Pennsylvania Association of Notaries This law firm is a debt collector attempting to collect this debt for our client and. any information obtained will be used for that purpose. Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 JUN-06-2007 04:09:53 '~: Last Name First/Middle Begin Date Active Duty Status Service/Agency BOOKAMIRE SHARON Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. ~ ~4-~- Mary M. Snavely-Dixon, Director Department of Defense -Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. #167;#167; 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: htt~//www.defenselink.mil/facf/pis/PC09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.millscra/owa/scra.prc_Select 6/6/2007 Request for Military Status Page 2 of 2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: WQHFRYTCDE https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 6/6/2007 C> ~ ~ -n :' c= -~-n -i#~ r ~~ '~' 'fir Q ~~ -- ~t ~ p - -L ~ H G `wt .F. ~ O O IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 07-2159-CIVIL vs. PRAECIPE FOR SATISFACTION OF JUDGMENT, SHARON L BOOKAMIRE Defendant(s) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Benjamin R Bibler, Esquire PA I.D. #93598 WELTMAN, WEINBERG & REIS CO., L,P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#5813444 DIS a IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. SHARON L BOOKAMIRE Defendant(s) Civil Action No. 07-2159-CIVIL 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. Sworn to and before me tU day of Noven NOTARY By : g Benjfir, Esquire PA WEEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #5813444 Notairlal Seal Wendy L. Gault, Nctanf Public City of Pittsburgh, Ally tmrly County My Coma?isspon E p ra ? 5 ,2014 tale'nber. pernS, va i..? n. 1 stn"