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Home My WebLink About07-4311 IN THE COURT OF COMMON PLEAS O[~ CtJMBERI,AND COUNTY, PENNSYI;VANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. CJ ~- ~/ 3 // Cu=.~ ~~" vs. COMPLAINT IN CIVIL ACTION NICOLE FARRAH BUMBAUCTH Defendant FIL~I3D ON BEHALF OF Plaintiff CO[JNSEL OF RF_,CORD OF 1'I-IIS PARTY: TAMES C. WARMBRODT, ESQUIRE PA T.D.#42524 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (41.2)434-7955 WWR#06003865 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL, DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. ~~- 5~3 // ~-! T~- NICOLE FARRAH BUMBAUGH Defendant COMPLAINT IN CIVIL ACTON 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 wit}un twenty (20) days after this complaint and notice are served, by enterilig a written appearance personally or by an attonley and 61ing in writing with the court your defenses or objections to the claims set forth against you. You are warned that iI' you fail to do so the case may proceed without you and a judgment may be entered against you by the court without fiuther 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 SI-COULD 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 SF,T FORTH BELOW TO FIND OtJT WHERE YOU CAN GET LEGAL HELP IF YOU CANNOT AFFORD TO HIRI~, A L,AWYF,R, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WI'L'LI INFOIZMA"PION AL30U"I' AGENCIES "THAT 1VI:AY OFT~ER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDl1CED 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 NLW ALBANY ROAD NEW ALBANY, OH 430.54-0000 . 2. Defendant is an adult individual residing at 293 OAK FLAT RD NEWVILLE,PA 17241 3. Defendant applied for and. received a credit card issued by Plaintiff bearing the account number 601 10021.00397496 . A true and correct copy ofPlaintiff s Statement of Account is attached hereto, marked as Exhibit `A" and made a part h~rcof. 4. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of 1LJNE 27, 2007, in the amount of $6113.90. 5. Defendant is in default of the terms of the Cardholder Agreement havin~~ not made monthly payments to Plaintiff thereby rendering the entire balance immediately due and payable. A true and. correct copy of Plaintiff's Cardholder Agreement is attached. as Exhibit "B". 6. Plaintiff avers that the Agreeme~~it between the parties provides that Defendant will pay Plaintiff's attorneys' fees. 7. Plaintiff avers that such attorneys' fees will amowit to $1000.00. 8. Although repeatedly renuested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, finance charges or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment h1 its favor and ag~ai~nst Defendant, NICOLE FARRAH BUMBAUGH individually, in the a»lount of $6113.90 with interest at the legal interest rate of 6`% per annum from date of judgment plus attorneys' fees of $1000.00, and costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINI3ERG & REIS, CO., L.P.A. JAMS . WARMBROD~I', ESQUIRE l'A I. .#4~ 24 Wel an, einberg & Reis Co., L.P.A. 271 Kop ers E3ldg. 4 ~ Sev th Avenue I ittsbL gh, I'A 1 S2l 9 (412 434-7955 WWR#:06003865 DISCOVER S6e,113.90Ce CARD .-_- ~~, 22 SDSN6A01 OOOS291 NICOLE BUMBAU6H 293 OAK FLAT RD NEWUILLE PA 17241-9463 Minimum Payment Dua Account Number 6011 0021 0039 7496 i $6,113.90 ~ Enter Amount Enclosed Below ~ ~ Payment Due Date ' ~ ~ ~' "~` May 21, 2007 Please make check payable to Discover Platinum Card. Minimum payment due includes a past due amount of ~ 1,703.00. Save time and a stamp this month by paying your bill online. To find out about our free and flexible online payment features, visit Discovercard.com/pay Address, e-mail or telephone dhangs~ Print change ins e above, or go to Discovercord.oom. Print your e-mail dress to receive important Account infarrndion and special offers. PO BOX 15251 ~~~"'~~""'~'~"~'~'~~"~ WILMINGTON DE 19886-5251 ~nr~~~r~u~u~r~u~n~~ur~r~ur~r~r~r~nn~~r~r~un~~~r~u~ 000006011002100397496061139000000000611390 Discover More Card Account Summary dosing Date: April 22, 2007 page 1 of 1 Account Number 6011 0021 0039 7496 Previous Balance 56,113.90 Payment Due Dote May 21, 2007 Payments And Crodits - 0.00 Minimum Payment Due 56,113.90 Purchases + 0.00 Credit Limit 65,000.00 Cash Advances + 0.00 Credit Available 60.00 Balance Transfers + 0.00 Cash Credit Limit 50.00 Finance Charges + 0.00 Cash Credit Available 60.00 New Balance = 66,113.90 Cashback Bonus Opening Cashback Bonus Balance s O.oo New Cashback Bonus Earned + 0.00 Cashback Bonus Balance 5 0.00 -:Cashback-Bonus®,4nniversctty------------------------AYSalabh~MRfl~eem------------- -----5--------O.QO----- Dare: May 22 How Can We Help You? ~ ~caant inga4;.s, "~° +" "° ae: Discover More Card, PO Box 30943 Please haw your Discover Card avaiable. Sah lake City, UT 84130 :Manage your account onlire d piscowrcard.com TDD (Telecommunications Device ter IFro Deaf): :.Customer Service: 1-800-DISCOVER X1-800-347-2683) For assistance, see roverse side. Transactions SO Fraud liability Guarantee Use your Discover Card with confidence. Information For You -Whit 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 ar this time. We have terminated, however, any inhodudory or promotional rate on purchases and any special balance hansfer rate and e s andard APR for purchases to your outstanding balance of purchases and balance transfers. However, w a ~ crease the APRs on your Account iF you fail to pay the '.minimum payment due by the payment due dot Plan section of the Cardmember Agreement for details. V j rw ',Finance Charge Summary Nominal Transaction Average Daily ANNUAL ANNUAL Periodic fee Doily Periodic PERCENTAGE PERCENTAGE FRVANCE FINANCE B c s Rates RATES RATES CHARGES CHARGES ':current billing period: 31 days .Purchases 50 0.04449% 16.24% V 16.24% 60 none :Cash Advances 50 0.05751 % 20.99% F 20.99% 60 60 .previous billing period: 22 days .Purchases 50 0.04449% 16.24% V 16.24% 60 none The rates that apply to your Account aro either fixed (F) or they may vary (V) 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 i~~~~ ~~~~~~ (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. ( ignature) WWR # 6003865 NICOLE FARRA BUMBAUGH 6011002100397496 ~ n,~ c.-a -..,r ~. `T7 C ~ ~ ~- tTi~ ~ -C '1J 'r, Fes, ~ ~ ~ ~ " v - '^~ ~, i , a', C w.~ ~~ ~ ~ SHERIFF'S RETURN - REGULAR CASE NO: 2007-04311 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS BUMBAUGH NICOLE FARRAH KENNETH GOSSERT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BUMBAUGH NICOLE FARRA the DEFENDANT at 0850:00 HOURS, on the 26th day of July 2007 at 293 OAK FLAT ROAD NEWVILLE, PA 17241 NICOLE BUMBAUGH 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 10.56 Affidavit .00 Surcharge 10.00 .00 Ffi~7lo~ '~,, 38.56 Sworn and Subscibed to before me this day of So Answers: ~-~ R. Thomas Kline 07/27/2007 WELTMAN WEINBERG REIS By: pu y She f A.D. R r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. NICOL FARrZA BUMBAUGH Defendant No. 07-4311-CIVIL TERM PRAEClPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF TH f S 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#06003865 a. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 07-4311-CIVIL TERM NICOL FARRA BUMBAUGH Defendant PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERL,~ND COUNTY: SIFT: 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. j. By. Attorney for P(ainti 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06003865 SWORN TO AND SUBSCRIBED before me this a~ day of u , 2007 NO ARY PUB w~~~yrw A, Janes, z~ , ,,,.;+, qp~r,:,; ~v wa,~,ty ~ ~~~~~ ,jV(~F, 29, 2010 Mer.::,.;r. ?°tmsylvanle Aleoc(atfor. ^~ No¢?,ies t.~ ~ d ~ ~ ~... ~~~ ~" rrt _ ~ ~., ~ %Y ~ x . : ,~ . ~ _ 4 ~ r£ ~M, ~ ~y" ~~ tv -~~ c.rs .. w