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Home My WebLink About07-5944 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. DONNA M BENNETT Defendant No : 6q - 5844 l JI U i l `Term 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 06191523 C A Pit WLG { IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No DONNA M BENNETT 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 0 COMPLAINT 1. Plaintiff, is a corporation with offices at 6500 New Albany Rd, New Albany, OH 43054. 2. Defendant is adult individual(s) residing at the address listed below: DONNA M BENNETT 3 CITADEL DR CAMP HILL, PA 17011 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011002660753351 . 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 September 26, 2007 , in the amount of $18308.54 . 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 $1500.00 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 , DONNA M BENNETT INDIVIDUALLY , in the amount of $18308.54 with interest at the legal rate of 6.000% per annum from date of judgment plus attorneys' fees of $1500.00 , and costs. Jame Warmbrodt,42524 WELT , WEINBERG & REIS CO., L.P.A. 436 Se enth Avenue, Suite 2718 Pi tsb rgh, PA 15219 ( 12) 34-7955 12-338-7130 619 523 C A Pit WLG This law firm is a debt collector tt pting to collect this debt for our client and any information obt i d will be used for that purpose. •- I ') 113,308.54 Payment Due Date August 14, 2007 15 SDSN6A01 0006203 DONNA BENNETT CITADEL CAMP HILL PA 17011-7614 Addres, e-mail or abovesor go to Discovelrcard com9Print yourre.mail o dra®ss receive important Account information and special offers. to 000006011002660753351183085400ooooo1 8311854 Discover More Card Account Summclry Account number ending in 3351 Cloa ng Date: P Wment Due Date Minimum Payment Du August 14, 2007 e Credit Limit $18,308.54 Available $15, 000.00 Cash Credit Limit $0.00 Cash Credit Availabl $0 00 e $0.00 July 15, 2007 Previous Balance Page 1 of 1 Payments And Credits Purchases $18,308.54 Cash Advances 0.00 + Balance Transfers 0.00 + Finance Char es + 0.00 New Balance 0.00 + 0.00 $18,308.54 'wasnback Bonusa Opening Cashback Bonus Balance New Coshback Bo $ Cashback Bonu ust 1 36 Anniversary bate: Au nus Earned 0'00 Cashback Bonus Bala 0'00 g nce Available to Redeem 0 00 How Can Weu Pl H 1 . $ 0.00 ease have your Dixove e P YObI. Mara 9e your For Account In u' ? to °a of Discover M account online at Discovercard.com Customer Service: 1.800. DISC ore Card pO Sah Lake City UT 84130 Box 30943 OVER (1- 800.347.2683) Transactio Fora i nmemunications Device far the Deco, see rever ns se side. $0 Fraud Liabilit y Guaran Information For Y tee Use Your Discover Card with ou confidence. While we are permitted under the Cardmember Agreement to increase the APRs on was late, we have chosen not t do so at this time. purchases and any special balance transfer rate, We have terminated, Your Account because your purchases and balance transfers, and applied however, an payment However, gthe standard APR for Y introductory or promotional rate on minimum payment due by the we reserve the right to increase the APRsuonhases to date. our Your if you ding balance of y details. payment duo See the Default Rate Plan section of the rdAcccount count if you fail to pay the Agreement for Finance Charge Summary Average Dail Nominal Daily Periodic ANNUAL ANNUAL Transaction current billin °^ s PERCENTAGE PERCENTAGE FPNMICE g per 30 days ° e RATES- RA-_ C Fee Purchases ES FINANCE D Cash Advances $0 0.07942% WOES- Previous billing period: 15 da $0 0.07942% 28.99% V 28.99% Purchases Ys 28.99% V 28.99% $0 $0 $0 none The rates that aPPI y 0.07942% 28.99% V $0 to your Account are either fixed F 28.99% $0 () or they may vary (V) as noted above. none I ' - nr number ending in 3351 Enter Amount Enclosed Below Pleasckpayable to Di Mmimum scover Card. paymeet due includes o amount of $4,002.00 past due Make a payment now or schedule one in advance. it, fast,s todeasy, Secure - and freel Visit uay at Dtscovercard.com/payments PO BOX 5D 111rrJ1"nn??h?h?„ WILMINGTON Er? 19886-5251 2?? VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsifications to authorities, that he/she is SIEC }'Lf"i .At Re- LL-(Name) Accounts Manager of DFS Services, LLC , plaintiff herein, that (Title) (Company) he/she 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 # 6191523 DONNA M BENNETT 6011002660753351 ? : ` ? ?' ? (? b ? ? o ? -fl (? _,._ _"' ..? v' ? ? ?J ? r ?_ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION December 6, 2007 DISCOVER BANK Plaintiff vs Civil Action No 07-5944 Civil Term DONNA M BENNETT Defendant RESPONSE TO: COMPLAINT AND NOTICE TO DEFEND In response to civil action filed against me by Discover Bank which was received October 31, 2007, by the Sherrifrs Department. 1 wish to request that a hearing be schedule in this matter. It was my understanding that this matter was being taken care of. Thank you for you consideration in this matter. Donna M Bennett 3 Citadel Drive Camp Hill, PA 17011 (717)737-6620 Originally sent November 19, 2007. Resent December 6, 2007. Respectfully Submitted, Donna M Bennett ;,. ? ,-? c'. .?.: S y; J T °? ?r? • • ...? } 1 f?.':r ?S^1? f`? -?f ^ w ,,?s p h J ? i ..?. ? y ? __ w.ia SHERIFF'S RETURN - REGULAR CASE NO: 2007-05944 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS BENNETT DONNA M STEPHEN BENDER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BENNETT DONNA M the DEFENDANT , at 1810:00 HOURS, on the 31st day of October at 3 CITADEL DRIVE CAMP HILL, PA 17011 by handing to DONNA M BENNETT 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 26.88 Affidavit .00 Surchargei?l 10.00 00 54.88 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 11/01/2007 WELTMAN WEINBERG REIS By: Deputy Sheriff A. D. 2007 It IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. DONNA M BENNETT Defendant No. 07-5944 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END WITH PREJUDICE 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. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6191523 ti IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 07-5944 CIVIL TERM DONNA M BENNETT Defendant PRAECIPE TO SETTLE AND DISCONTINUE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR Please kindly Settle and Discontinue the above-captioned matter upon the records of the Court and mark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. PAI.D.#+ 1400 Kop 436 Sev Pittsbur 1 (412) 4 SWORN TO AND SUBSCRIBED before me this ?? day V- in Q8 of NOTA Y PUBkLV brodt, Esquire s Building Avenue A 15219 1523 TH OF PENNSYIvANIA Notarial Seed Welly L Gault, Notary Pubic Gly Of PAteburo' Meg" catft Illy CorMbWM EVWM July 15, 2D10 Member, Penntylvanla Aatoclatlon of Nohrlst a '? -+'z ?;;,, ? t - +? ?