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Home My WebLink About07-2392IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. FRED W CORKLEJR Defendant No : &r -- -234;, C', c L COMPLAINT IN CIVIL ACTION 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 05430308 C A Pit WLG r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. FRED W CORKLEJR Defendant Civil Action No 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: FRED W CORKLEJR 112 HUTTON LEMOYNE, PA 17043 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011002690549266 . 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 April 10, 2007 , in the amount of $2145.29 . 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 $300.00 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 , FRED W CORKLEJR INDIVIDUALLY , in the amount of $2145.29 with interest at the legal rate of 6.000% per annum from date of judgment plus attorneys' fees of $300.00 , and costs. xyl--? Jame . Warmbrodt,42524 EL WEINBERG & REIS CO., L.P.A. 4nth Avenue, Suite 2718 Pgh, PA 15219 (F -338-7130 0 C A Pit WLG This law firm is a debt collector ayte pting to collect this debt for our client and any information obt i d will be used for that purpose. R new balance $2,715.29 PA RD 19 SDSN6A01 0005554 FRED CORKLEJR PO BOX 56 LEMOYNE PA 17043-0056 minimum payment due $331.00 payment due date August 18, 2006 Address, a-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 0026 9054 9266 enter amount enclosed below $ Please make check payable to Discover Platinum Card. You are overlimit. Pay the sum of the monthly minimum payment plus the overlimitZamount of $815.29. LJ? Avoid fees by signing up for timely e-mail reminders. Get alerts when your payment due date is coming up and more. Go to Discovercard.com/rem inders PO BOX 15251 11181111""""''I""1111 WILMINGTON DE 19886-5251 000006011002690549266027152900000000033100 Discover Platinum Card Account Summary account number payment due date minimum payment due credit limit credit available cash credit limit cash credit available 6011 0026 9054 9266 August 18, 2006 $331.00 $1,900.00 $0.00 $1,100.00 $0.00 Closing Date: July 19, 2006 previous balance page 1 of 2 $2,614.92 payments and credits - 0.00 purchases + 39.00 cash advances + 0.00 balance transfers + 0.00 FINANCE CHARGES + 61.37 new balance = $2,715.29 You may be able to avoid Periodic Finance Charges, see the reverse side for details. Cashback Bonus® Opening Cashback Bonus Balance New Cashback Bonus Earned Cashback Bonus Balance Available to Redeem Cashback Bonus® Anniversary Date: November 19 $ 0.62 + 0.00 $ 0.62 $ 0.00 Transactions trans. post V U date date t Other/Miscellaneous Jul 19 Jul 19 LATE FEE 1 $ 39.00 Your Account is overlimit While we are permitted under the Cardmember Agreement to charge you an Overlimit Fee, we have chosen not to_do so at.this time. We reserve the.right to.d_o so if, as of the close of a billing period, your outstanding Account balance exceeds your Account credit limit. See the Overlimit Fee section of the Cardmember Agreement for details. While we are permitted under the Cardmember Agreement to increase the APRs on your Account because your payment was late, we have chosen not to do so at this time. We have terminated, however, any introductory or promotional rate on purchases and any special balance transfer rate, and applied the standard APR for purchases to your outstanding balance of purchases and balance transfers. However, we reserve the right to increase the APRs on your Account if you fail to pay the minimum payment due by the payment due date. See the Default Rate Plan section of the Cardmember Agreement for details. """' ATTENTION """' ATTENTION ""*'* ATTENTION '* ..... ATTENTION "'""' ATTENTION """' P 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. 6 (Signature) WWR # 5430308 FRED W CORKLEJR 6011002690549266 44 ? C SIT' r?rT; Y ' . /-- ? ? CJ) ? ?7 lam. ` p G,3 'K IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. FRED W CORKLEJR Defendant No. 07-2392-CIVIL PRAECIPE TO REINSTATE COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire PA I.D. #42524 WELTMAN, WEINBERG & REIS, CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05430308 4, IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. FRED W CORI{LEJR Civil Action No. 07-2392-CIVIL Defendant PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. arm rodt, Esquire PA I.D. # 2524 WELT AN, INBERG & REIS CO., L 2718 opper uilding P A 436 ven Avenue Pitt ur , PA 15219 (41) 4-7955 WWR #05430308 co } Ca . ? K IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. FRED W CORKLEJR Defendant No. 07-2392-CIVIL PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE 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. 1400Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05430308 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 07-2392-CIVIL FRED W CORKLEJR Defendant PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR: Settle, Discontinue and End the above-captioned matter upon the records of the Court without prejudice to refile and mark the costs paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: Attorney for Plaintiff 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05430308 SWORN TO AND SUBSCRIBED before me this 17 day of n 008 c - NO RY PUB E _- s?? ??? °?? c__ ?:;; ;? ._ ?? <, --',:?-, `_