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Home My WebLink About07-4902 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: D']- 49pa C+vtt Term vs. COMPLAINT IN CIVIL ACTION HANY ABOU ABDOU AKA HANY ABOUABDOU 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 06003851 C A Pit WLG IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. HANY ABOU ABDOU AKA HANY ABOUABDOU Defendant Civil Action No O'1- Y 9bd ~~ T'u'"` 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: HANY ABOU ABDOU 300 N 2ND STREET WORMLEYSBURG, PA 17043 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011002090327164 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 June 27, 2007 in the amount of $3769.27 . 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 HANY ABOU ABDOU ,INDIVIDUALLY in the amount of $3769.27 with interest at the legal rate of 6.000 per annum from date of judgment plus attorneys' fees of $500.00 and costs. James Warmbrodt,42524 WELT WEINBERG & REIS CO., L.P.A. 436 S ve th Avenue, Suite 2718 Pitt bur h, PA 15219 (41 ) 4 4-7955 F 4 -338-7130 06 03 1 C A Pit WLG This law firm is a debt collector att/emplting to collect this debt for our client and any information obtai e will be used for that purpose. 1tc~-- • •-•• ~~•~•~~~ '~-vi3~. 53,769.27 ...r~rr~~w~~r ~uyruenr vue S324.00 ~ Hccounr Number OU 1 I UUlU 9032 7164 Enter Amount Enclosed Below ! ~ CARD ! ~ ~ ; ,. ~.f ,,. 1 ~`_ _ Payment Due Date $ ) .' .~ ~, , ~ ~ ~, f '"r ~ ~ May 17, 2007 .. Please make check payable to Discover Platinum Card. You are overlimit. Pay the sum of the th) i i 18 SDSN8A01 0009277 mon y m n mum payment plus the overlimit amount of x269.27. HANY ABOU ABDOU Save time and a stamp this month by paying 300 N 2ND ST your bill online. To find out about our free WORMLEYSBURG PA 17043-1103 and flexible online payment features, visit Discovercard.com/pay PO BOX 15251 ~~~ns~~nnn~~~u~nn~~~ Address, o-mail or telephone change3 Print change in sppace WILMINGTON DE 19886-5251 above, or go to Discowrcard.com.Printyouro-mailaddressto ~"'~~~'~"~"~~~u~u~~in~~~u~~i~~~~~nn~~~~~~un~~~~~n~ receive important Account information and special offers. 000006011002090327164037692700000000032400 Discover More Card Account Summary Closing Date: Account Number Payment Due Date Minimum Paymsnf Due Credit limit Credit Available Cash Credit Limit Cash Credit Available 6011 0020 9032 7164 May 17, 2007 5324.00 $3,500.00 So.00 S 1,800.00 so.oo April 18, 2007 page 1 of 2 Previous Balance $3,620.98 Payments And Credits _ 0 ~ Purchases + 78 00 Cash Advances Balance Tranafers + 0.00 Finance Charges + 0.00 + 70 29 New Balance $3,769.27 You may be able to avoid Periodic Finan ce Charges see the reverse aide For detoils. , Cashback Bonus® Opening Cashback Bonus Balance $ 14.37 New Cashback Bonus Earned + 000 Cashback Bonus Balance S 14.37 Cashback Bonus® Armiversary - . _ .. _ .. - ... _ . _ AYQl~gble FQ ltedesm _ - _ S Date: June 18 - - - - - - - - - . _ ...0,00- . - How Can We Help You? For Account Inquirisa, writs b us ah ,Pleats haw your Diuowr Cord avaiabls. Discover More Card, PO Box 30943 Manage your account online at Discovercard.com Salt Lake City, UT 84130 Customer Service; 1-800-DISCOVER (1.800-347.2683) For auistan emsee~reverse~de.e ~ ~e D°af): Transactions $0 fraud Liability Guarantee Use your Discover Card with confidence. Trans. Poet Date Dab Other/Miscellansoua Apr 18 Apr 18 OVERLIMIT FEE Apr 18 Apr 18 LATE FEE $ 39.00 39.00 Information For You While we are permitted under the Cardmember Agreement to increase the APRs on your Accovnt 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 rightta increase the-APRs on your AccounhiF 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 * * * Your account is seriously past due. Payment of the amount due and arrangements For future payments should be made immediately. Through generous Cardmembers like you, Discover(R) Cord has donated more than x15 million to the Mako-A-Wish Foundation(R). Consider contributing your Cashback Bonus to the Make•A-Wish Foundation to help make a child's dream come true. To further your donation, Discover will add an additional 20%. Visit www.discovercard.com or www.wish.org EXHI~I VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to r unsworn falsifications to authorities, that he is ~ (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 # 6003851 HANY ABOU ABDOU 6011002090327164 ~ ~ ~ r '~ .. .a .~~ O --, ; ~ ..,.~ n~ -_~ R~ - D ._.. _~ c_ S~ oo D ~ ; ~- , y .. _ } • -r ~~ c.. -~ SHERIFF'S RETURN - REGULAR CASE NO: 2007-04902 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS ABDOU HANY ABOU ET AL JASON VIORAL Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within NOTICE was served upon ABDOU HANY ABOU A/K/A ABOUABDOU HANY the DEFENDANT at 0013:08 HOURS, on the 23rd day of August 2007 at 300 N 2ND STREET WORMLEYSBURG, PA 17043 ROSE M. WILLIAMS (MOTHER IN LAW a true and attested copy of NOTICE COMPLAINT together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 14.40 Affidavit .00 Surcharge 10.00 .00 4`l7L~D'1 ~..., / 4 2 .4 0 Sworn and Subscibed to before me this day of , by handing to So Answers: R. Thomas Kline 08/29/2007 WELTMAN, WEINBERG & REIS By: p ty Sheriff A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. HANY ABOU ABDOU Defendant No. 07-4902 CIVIL TERM 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. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06003851 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 07-4902 CIVIL TERM HANY ABOU ABDOU 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#06003851 SWORN TO AND SUBSCRIBED before me this o~1 day of o , NOT Y PUBLIC COMMONWEALTH OF PENNSYLVA A Nota~iat Seat Were ^ ~;:~ - . ,,.-~~ ___._..~....~ ~.~......."r'% y. .~ ~~? __.~ ~} t.. ~.,._ ,;1 : ; i .a ~ .. J ,,,,,,,,~nwrr+M. ~sf .- .. s^~t"r~l