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Home My WebLink About07-3195IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: Q^f ._ ~~ vs. COMPLAINT IN CIVIL ACTION HAROLD WILLI GORDON 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 05877377 C A Pit CXC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No HAROLD WILLI GORDON 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: HAROLD WILLI GORDON 50 MOUNTAIN VIEW TER NEWVILLE, PA 17241 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011002440165033 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 May 16, 2007 in the amount of $5004.28 . 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 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 HAROLD WILLI GORDON ,INDIVIDUALLY in the amount of $5004.28 with interest at the legal rate of 6.OOOg per annum from date of judgment plus attorneys' fees of $500.00 and costs. James WELTM 436 Pitt (41 FAX 05 77 This law firm is a debt collector at our client and any information obtai Warmbrodt,42524 EINBERG & REIS CO., L.P.A. h Avenue, Suite 2718 PA 15219 -7955 338-7130 C A Pit CXC ng to collect this debt for 11 be used for that purpose. .... _ 08 SDSN8A01 0006118 fi. `;' ~' ; °'; HAROLD GORDON ~ Save time and a stamp this month by paying ... 50 MOUNTAIN VIEW TER "' ~ ,, your bill online. To find out about our free NEWVILLE PA 17241-9025 `' -^..-`' and flexible online payment features,visit Dlscovercard.comJpayments PO BOX 15251 ~~~s~r~~~~~~~s~r~~~~s~r~~~~ WILMINGTON DE 19886-5251 Address, e-mail or telephone change8 Print change in space ~~~)I) ( )~~)~li~)~~)I~~~I~'~~~I~I~~~)~r~~'I~I~'~~~~~II~I~~' above, or go to Discovercard.com. Print your email address to I ~ ~~ receive important Account inFormation and special offers. 0000060110024401650330500428D0000000500428 Discover Platinum Card Account Summary Closing Date: ,Account Number ;Payment Due Date ;Minimum Payment Due 'Credit Limit :Credit Available ,Cash Credit Limit ;Cash Credit Available 6011 0024 4016 5033 February 7, 2007 $s,oo4.2s $6,800.00 $0.00 $0.00 ~CHI~IT January 8, 2007 page 1 of 1 Previous Balance $5,004,28 Payments And Credits 0,00 Purchases + 0.00 Cash Advances + 0.00 Balance Transfers + 0.00 Finance Charges + 0.00 New Balance $5,004.28 Cashbac 011tlS Opening Cashback Bonus Balance $ ~ 0.00 New Cashback Bonus Earned + 0.00 Cashback Bonus Balance $ 0.00 Gashback Bonuses Armiversary - - - - - - - - - - - - - - - - - - -Available to_Redeem _ _ _ _ _ _ _ _ _ _ . _ _ _ _ $- _ _ _ _ _ _ OAO_ Date: September 8 ;How Can We Help You? For Account hquiries, write ro u: at: ;Please haw your Diacowr Card available. Discover Platinum Card, PO Box 30943 Salt Lake City, UT 84130 ;Manage your account online at Diseowrcarcl.com TDD (Telecommunications Device iPor 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 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 rata, and applied the standard APR for purchases to your outstanding balance of purchases and balance TansFers. 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. Ses the Default Rats Plan section of the Cardmembsr Agreement For ;details. 1__.. _. _.. .. _... . _. __--. .__._.__. I I I ;Finance Charge Summary Nominal Transaction ! Average Daily ANNUAL ANNUAL Periodic Fee Daily Periodic PERCENTAGE PERCENTAGE FINANCE FINANCE I ces Rates RATES RATES CHARGES GES ;current billing period: 31 days Purchases $0 0.07189% 26.24% V 26.244'a $0 none ;Cash Advances $0 0.06025% 21.99% F 21.99% $0 $0 ;previous billing period: 8 days ;Purchases $0 0.07189% 26.24% V 26.24% $0 none ;The rates that apply to your Account are either Fized (F) or they may vary N~ as noted above. 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 hislher knowledge, information and belief. (Signature) WWR # 5877377 HAROLD WILLI GORDON 6011002440165033 (~ -~. ~~. b b u 1\' V F -1- t7 .~. t ~y ~.~:: _ Grp. ~ f_ A ~-^' N ca 0 V -~ N 'T3 trJ c.+,) .fi' ~~ .; C.l~ O :~- SHERIFF'S RETURN - REGULAR CASE N0: 2007-03195 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS CORDON HAROLD WILLI RICHARD SMITH Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CORDON HAROLD WILLI the DEFENDANT at 1103:00 HOURS, on the 7th day of June 2007 at 50 MOUNTAIN VIEW TERRACE NEWVILLE. PA 17241 by handing to 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 10.56 Affidavit .00 Surcharge 10.00 00 4 ~16Iar? ~ 3 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 77 06/11/2007 WELTMAN WEINBERG I By: eputy Sheriff A.D. IN THE COURT OF COMMON PLEAS OF CUMBF.R.LAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK. Plaintiff vs. HAROLD WILLI GO:RDON Defendant No. 07-3195-CNIL-TERM PRAECIPE FOR ENTRY OF JUDGMENT BY CONSENT 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#05877377 IN THE COURT OF COMMON~PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK. Plaintiff vs. HAROLD WILLI GORDON Defendant Civil Action No. 07-3195-CIVIL-TERM PRAECIPE FOR JUDGMENT BY CONSENT TO THE PROTHONOTARY: Kindly enter Judgment against Defendant, HAROLD WILLI GORDON, in the amount of $5504.28 plus costs, based upon the consent of the parties. CONSENTED TO: WELTMAN, WEINBERG & REIS CO., L.P.A., By: ---...----------- Attorney for Plainti HAROLD WILLI GORDON, By: _ Defen ant WWR#05877377 IIV THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 07-3195-CIVIL-TERM HAROLD WILLI CORDON Defendant STIPULATION OF THE PARTIES FOR PAYMENT AND FOR THE ENTRY OF JUllGMENT BY CONSENT "TO THE PROTHONOTARY: Kindly enter Judgment in favor of Plaintiff and. against the Defendant, HAROLD WILLI CORDON, above- named, in the amount of $5504.28 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 $5004.28 with continuing interest thereon at a rate of 6.00% per annum from JUNE 22, 2007, plus attorneys' fees in the amount of $500.00 and costs. To secure the repayment of said indebtedness, Defendant agrees that Judgment 6y Consent will be enured in favor of the Plaintiff and against the Defendant, HAROLD WILLI CORDON, in the amount of $5004.28 plus continuing interest thereon at the rate of 6.00% per annum from J UNE 22, 2007, plus attorneys' fees in the amount of $500.00 and costs. 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) $248.00 due by 07/15/07; (b) no less than $248.00 per month due on the l 5TH. day of each consecutive month thereafter unfit 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 this _day of , 20 WELTMAN, WEINBER.G &REIS CO., L.P.A.. By. /' Y .. William. T. Molcz ,Esquire PA LD. #47437 WELTMAN, WEINBERG &REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#05877377 By: - ~. D en ant, H OLD WI ,LI CORDON P ~'o -4 ..o • O ~ ~ o * ~ ~ ~ ~ ~ ~ 0 ~ c~ ' CeJ C~ ~ v1 N ?J ~-=~ ~ .:. ~ ~~W ~. ~j N 4~ D ~'. ~ ~ ~rsz ~ t ~ ~ s-' ~ ~ ca ~ gi $ k IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION D[SCOVER. BANK Plaintiff vs. Civil Action No. 07-3195-CIVIL-TERM. HAROLD WII,LI GOR.DON Defendant HAROLD WIL.LI GORDON 50 ti10UNTAIN VIEW TER NEWVILLE,PA 17241 NOTICE OF JUDGMENT OR ORDER TO: ( )Plaintiff (xx) Defendant ( )Garnishee You are hereby notified that the following Order or Judgment was entered against you on (xx) Assumpsit Judgment in the amount of $5504.28 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: v,ra PROT ONOTARY( IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. HAROLD WILLI GORDON Defendant No. 07-3195-CIVIL-TERM 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., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05877377 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 07-3195-CIVIL-TERM HAROLD WILLI GORDON 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. William T. Molczan, E uire PA. I.D.#47437 WELTMAN, WEINBERG &REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #05877377 Sworn to and su~ ~ibed before me this day of September, 09 ,~ O~CRY P~[IC COMMON1NEAl.~li 6~ ~~AIW Notarial Seal Wayne A. Jones, Notary Public City Of Plttsburpb, Albpheny County M Commieslon June Z>i, 2010 Mem er, Pennsylvania ABSOCiatlon of Notarbs 2~~9 ~E~ ~ i ~ ~~t 2.~ u =, CU~~r~~~ _ :,~„ ~~ ~8.OO PIA A't'K erg 84 I ~ 117 aaos~4