The URL can be used to link to this page

Home My WebLink About07-2870IN THE COURT !.)F COMMGN PLEAS OF CUMBERL:4ND COUNTY, °EI7PdSYLVANTA CIVIL DIVISIOi~] DISCOVrR BANK nn h.luintif~' I3o: O7- oZ1'7~ ~ ~~ ~~L ~' ~ ~S. COb9PLAII`TT IN CIVIL ACTION DEDTNIS J fIA3ERICH Defendant: FILED ON BEHALF OF Plai:n.ti.f~' COUNSEL OF RECORD OF THIS PARTY: James C. ~i~Tarmbro~=~t, 42524 WLI,Tb1An?, WEINBEKG & REIS CO:, L.P.A. 436 Se~~~r_:::-~ A~;aryL.e, S;aiye 271~t Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 05878315 C A Pit ~VLG IN THE COURT OF COMN:ON PLEAS OF CUMBERLAI~ID COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No DENNIS J HAGERICH Defendant COMPLAINT AND NOTICE TO DEFEND You have been sued ir_ court. If you wish to defend against the claims set forth in the following page, you must take action within twenty (20) days after this complaint and notice are served, by entering a writ~en appearance personally or by an attorney and filing in writing with the cour`~~ ~rour 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 propF.rty 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 MAI' BE ABLE TO PROVIDE YOiJ WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERRAI~ SERVTCE CUMBERLAND COUNTY BAR ASSOCIATIOh~ 32 SOUTH BEDFORD STREET ChI~.L1SLE, Pti 1'i CJ..i (7171 249-3166 x ~~ ;~; ,._ -. -~ ,. ~t COMPLAIDIT 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: DENNIS J HAGERICH 3409 LOGAN ST CAMP HILL, PA 17011 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011298833089091 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 27, 2007 in the amount of $2903.65 . 5. Defendant i~ 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 . 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 DENNIS J HAGERICH ,INDIVIDUALLY in the amount of $2903.65 with interest at the legal rate of_6.000°s per annum from date of judgment plus attorneys' fees of $500.00 and costs. r _ Jam fC. Warmbrodt,42524 WE'L'T WEINBERG & REIS CO. , L.P.A. 436~~Se nth Avenue, Suite 2718 Pit~tsbu gh, PA 15219 (4'x.2) . 4-7955 F Y: 4~ 2-338-7 x_30 0~8 7 83,15 C A P t WLG This law firm is a debt collector at~tem ing to collect this debt for our client and any information obta~ne ~~~ill be used for that purpose. New Balance Minimum Payment Due Account Number 6011 2988 3308 9091 ~ISCC~VER $2,903.65 $2,903.65 Enter Amount Enclosed Below CARD Payment Due Date March 21, 2007 please make check payable to Discover Platinum Card. Minimum payment due includes a past due amount of $195.00. 22 SDSN6A01 0007055 '`~ t ~^~ DENNIS HAGERICH ~ ~ 1 r:~ ~ { ..~ Save time and a stamp this month by paying 3409 LOGAN ST ,.,;-~ your bill online. To find out about our free ti (c W ~° t ~€ and flexible online payment features, visit CAMP HILL PA 17011-27 0 Discovercard.com/payments PO BOX 15251 ~~~rrr~~rrrri~~~rr~r~r~~rr~ pac WILMINGTON DE 19886-5251 above, or goato Dix~ovehrcoard com~Print~nyour e•mailnaddreess to ~ur~~~r~u~u~r~u~n~~ur~r~nr~i~r~r~un~~r~r~un~~~r~u~ receive important Account information and special offers. 000006011298833089091029036500000000290365 I Discover Platinum Card Account Summary Closing Date: AAccount Number PPayment Due Date ;Minimum Payment Due :Credit limit .Credit Available ,Cash Credit limit ,Cash Credit Available 601 1 2988 3308 9091 March 21, 2007 $2,903.65 $6,000.00 $0.00 $0.00 $0.00 February 22, 2007 page l of 1 Previous Balance $2,903.65 Payments And Credits - 0.00 Purchases + 0.00 Cash Advances + 0.00 Balance Transfers + 0.00 Finance Charges + 0.00 New Balance = $2,903.65 Cashback Bonus® Opening Cashback Bonus Balance $ 0.00 ~ New Cashback Bonus Earned + 0.00 Cashbadc Bonus Balance $ 0.00 GashbaclrBonus~Anniversary-------- ------- --------AvAFlablebRedesro_-- - -------_ ___-. $- __ __--0.00-- _-. Date: June 22 ;How Can We Help You? For Account Inquiries, writs to us ah. Discover Platinum Card, PO Box 30943 Please have your Discover Card ava~abk. Sak lake City, UT 84130 Manage your account online of Discovercard.com TDD (Telecommunications Device for the Dsefl: 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 Use your Discover(RI Card to make a $100 donation to The Statue of LibertyEllis Island foundation, Inc. and you can have the name of someone you care about engraved on The American Immigrant Wall of Honor(R), built to celebrate freedom and commemorate American Dreams. For more information keg on to Discovercard.com ;Put your home's equity to good use ...with smart home equity financing `ans. We offer a full ran8e ~oF home equity credit line options at bw rates -apply online at Discoverho . o and get a response in just 30 1secondsl Please reFerence invitation number DCS207207N_when you apply_ i - i ;Finance Charge Summary . Nominal Transaction Avers a Daly ANNUAL ANNUAL Daily g Periodic PERCENTAGE PERCENTAGE FefMA~NCE FINANCE Balances Rates RATES RATES CHARGES CHARGES current billing period: 31 days Purchases $0 0.06847% 24.99% F 24.99% $0 none Kash Advances $0 0.06847% 24.99% F 24.99% $0 $0 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 # 5878315 DENNIS J HAGERICH 6011298833089091 f Y.:, ,,"Y. .~ ~../ ~ ~~ :J ~' a C:. c;~a J V ~ - ` w ~ ~ ~ ~ ~-~ 1'T ~~ ..,r' C iT :-, c~, .> r~i ..~ SHERIFF'S RETURN - REGULAR CASE N0: 2007-02870 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS HAGERICH DENNIS J SHANNON SHERTZER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HAGERICH DENNIS J the DEFENDANT at 1830:00 HOURS, on the 15th day of May 2007 at 3409 LOGAN STREET CAMP HILL, PA 17011 by handing to HARRY HAGERICH FATHER 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: Docketing 18.00 Service 13.44 Affidavit .00 Surcharge 10.00 00 >I3 r`b 7 l.~ 4 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline i' 05/16/2007 WELTMAN WEINBERG REIS By ~. !/ eputy Sher f A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. DENNiS J HAGERICH Defendant No. 07-2870 CNIL TERM PRAECIPE TO SETTLE AND DISCONTINUE 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 Building 436 Seventh. Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05878315 i ' "' IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 07-2870 CIVIL TERM DENNIS J HAGERICH 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. WELTMAN, WEIN ERG & REIS CO., L.P.A. By: ~~!/ William T. Molczan, quire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#0587831.5 Sworn to and subscribed Before me the ~___ Day~~~+; 2/007 ~,1~ ~` NO ARY PU IC ~9MM@hiWf~ ~b~..:l~EWi*1~i'+~-~ApJIA .,,.,. y~lart~, .,,;;~! WByrtt- A. ,~ane~. t•dr~iry Pukes ~y O[ Pll~abupSi~~ 1~ilegttanY ~~ My Commisslan Pxplr~ Juns 20, ~p'i0 Member, Pennsylvania Assoclatlon of D1oRas-es r~ ('~ -~ ~ ~ ~~~ ~ ~~~ ~ ~ is ~ = :>~ r rs ~ r- . ~ ~ - .