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Home My WebLink About07-22664 h IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: VS. COMPLAINT IN CIVIL ACTION PATRICIA L FINKENBINDER 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 05758623 C A Pit WLG OP IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No PATRICIA L FINKENBINDER 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 U 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: PATRICIA L FINKENBINDER 22 LOCUST LN (POB 16) PLAINFIELD, PA 17081 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011002480552363 . 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 29, 2007 , in the amount of $4284.91 . 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 $500.00 . 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 , PATRICIA L FINKENBINDER INDIVIDUALLY , in the amount of $4284.91 with interest at the legal rate of 6.000°6 per annum from date of judgment plus attorneys' fees of $500.00 , and costs. James C . WELTMAN, 436 Se en Pitts urg (412)! 434 FAX: 412- 057 8623 armbrodt,42524 INBERG & REIS CO., L.P.A. F t Avenue, Suite 2718 F3 PA 15219 7955 38-7130 C A Pit WLG This law firm is a debt collector att&tAg to collect this debt for our client and any information obtai ed ill be used for that purpose. New Balance DISC ?V R $4,284.91 CARiY 15 SDSN6A010010059 PATRICIA FINKENBINDER PO BOX 16 PLAINFIELD PA 17081-0016 Minimum Payment Due Account Number 6011 0024 8055 2363 $4,284.91 Enter Amount Enclosed Below Payment Due Date $ ;L3 January 14, 2007 Please make check payable to Discover Card. Minimum paymant due includes a past due amount oFS798.00. Consolidate bills quickly and securely with a Balance Transfer to your Discover Card - Call 1-877-353-0989 or visit Discovercard.com/balancetransfer TODAY! PO BOX 15251 IIIruIIunrlIIeIrInIuII ssppaa WILMINGTON DE 19886-5251 Address, e-mail or telephone change? Prix cchanmailnaddraee t above, or o to Discovercard.com. Print receive important Account information and special offers. 000006011002480552363042849100000000428491 Discover Card Account Summary Closing Date: December 15, 2006 page 1 of 1 Account Number Payment Due Date Minimum Payment Due Credit Limit Credit Available Cash Credit Limit Cash Credit Available 6011 0024 8055 2363 January 14, 2007 $4,284.91 $4,900.00 $615.00 $0.00 $0.00 Previous Balance $4,284.91 Payments And Credits 0.00 Purchases + 0.00 Cash Advances + 0.00 Balance Transfers + 0.00 Finance Charges + 0.00 New Balance = $4,284.91 Cashback Bonus® Opening Cashback Bonus Balance $ 0.00 New Cashback Bonus Earned + 0.00 Cashback Bonus Bakmce $ 0.00 -Cashback-Bonus®Annivernary ------------------------Avaikilale-to- ettl------------ _0.00-- - Date: December 15 How Can We Help You? For Account Inquiries, write to us at. Please have your Discover Card availlable. Discover Card, PO Box 309,43 Salt Lake City, UT 84130 Manage your account online at Discovercard.com TDD (Telecommunications Device for the Dea fl: 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 1 Make-A-Wish Foundation(R). You can make a child's dream come true by electing to donate s I) to the Make-A Wish Foundation. To learn how, lease visit Discovercard.com or visit Wi Finance Charge Summary oo--- , Average Daily Nominal ANNUAL ANNUAL Periodic Transaction Fee Daily Balances Periodic R t PERCENTAGE RATES PERCENTAGE FINANCE FINANCE a es RATES CHARGES CHARGES current billing period: 30 days Purchases $0 0.05477% 19.99% F 19.99% $0 none Cash Advances $0 0.06025% 21.99% F 21.99% $0 $0 L:II:__ -_-:_J. 1A J-.- 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 # 5758623 PATRICIA L FINKENBINDER 6011002480552363 44 N v N 0 ? O cn cm G Cl) SHERIFF'S RETURN - REGULAR CASE NO: 2007-02266 P COMMONWEALTH O PENNSYLVANIA: COUNTY OF CUMB RLAND DISCOVER BANK FINKENBINDER PATRICIA L MARK CONKLIN Sheriff or Deputy Sheriff of Cumberland Coun y,Pennsylvania, who being duly sworn according to law, says, the withi COMPLAINT & NOTICE was served upon FINKENBINDER PA RICIA L the DEFENDANT at 22 LOCUST at 1730:00 HOURS, on the 8th day of May , 2007 PLAINFIELD, PA 17081 PATRICIA FI INDER by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same Mime directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 5.76 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 51,2yfo7 33.76 05/09/2007 WELTMAN WEINBERG REIS Sworn and Subsci ed to By: before me this day Deputy Sheriff of A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. PATRICIA L FINKENBINDER Defendant No. 07-2266 PRAECIPE TO SETTLE AND DISCONTINUE FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PAID. #47437 WILTMAN, WEINBERG & REIS CO., L.P.A. 27118 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05758623 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 07-2266 PATRICIA L FINKENBINDER Defendant PRAECIPE TO SETTLE AND DISCONTINUE TO THE PROTHONOTARY OF COUNTY: Please kindly Settle and Discontinue the above captioned matter upon the records of the Court and mark the cost paid. Sworn to and subscribed Before me the P9 P Day of SEPTEMB 2007 /• NO ARY PUB /C WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WELTMAN, WEINBERG & REIS CO., L.P.A. By: W William T. Molcz , Esquire PA I D #47437 WWR#05758623 (;j'% ' '0NWEALTH OF Pt_NNN AN;A Nlo?alrial Seel ,y'n9, ,k-,nm, Nalwv qv c,, nmission E); ire .:.! K, 2S. L Member ?ennsAvania Associa±i? _?? ??, ....? p ?;? } tV ? ?;, r..... ?.r