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HomeMy WebLinkAbout03-5655Our File No. 166760 ATTORNEYS FOR PLAINTIFF ERIC M. BERMAN, P.C. BY: Eric M. Berman, Esquire, I.D. 83698 BY: Robert M. Kline, Esquire,I.D. 56479 198 Allendale Road, Suite 306 King of Prussia, PA 19406 (610) 265-7720 DISCOVER BANK c/o ERIC M. BERMAN, P.C. 198 Allendale Road, Suite 306 King of Prussia, PA 19406 COURT OF COMMON PLEAS COUNTY OF CUMBERLAND TRIAL DIVISION CIVIL ACTION Term JAMES H MILLER 521 QUAIL CT MECHANICSBURG, PA 17050 2083 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 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 this complaint or for any other claim or relief required 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 ~)U DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET ~)RTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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 REFERENCE SERVICE COUNTY OF CUMBERLAND BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PA 17013 800-990-9108 Our File No. 166760 ATTORNEYS FOR PLAINTIFF ERIC M. BERMAN, P.C. BY: Eric M. Berman, 83698 BY: Robert M. Kline, 56479 198 Allendale Road, King of Prussia, PA (610) 265-7720 DISCOVER BANK c/o ERIC M. BERMAN, P.C. 198 Allendale Road, Suite 306 King of Prussia, PA 19406 VS. COURT OF COMMON PLEAS COUNTY OF CUMBERLAND Esquire, I.D. Esquire,I.D. Suite 306 19406 CIVIL ACTION __ Term No. 03 -- ~d~3~ JAMES H MILLER 521 QUAIL CT MECHANICSBURG, PA 17050 2083 COMPLAINT 1. Plaintiff, DISCOVER BANK , is a DELAWARE STATE BANK authorized to do business in the Commonwealth of Pennsylvania with its place of business at 3311 MILL MEADOW DRIVE, HILLIARD, OH 43026. 2. The Defendant(s), JAMES H MILLER , resides at 521 QUAIL CT , MECHANICSBURG, PA 17050-2083. 3. There is due from the Defendant(s) the sum of $3,334.05 for credit extended by Plaintiff to Defendant(s), acct. no. 6011003917517540, and which such credit was drawn and used by the Defendant(s). Defendant(s) is in default for failure to make payments for such use. 4. The Plaintiff has made demand upon the Defendant(s) for payment of monies in the sum of $3,334.05 advanced to Defendant(s) through Defendant(s) use of the above-referenced credit account, but Defendant(s) has failed and refused to pay the said sum or any part thereof. 5. Ail applicable credits, if any, have been duly applied to Defendant(s) credit account. WHEREFORE, Plaintiff claims of the Defendant(s) the sum of $3,334.05 plus interest, attorneys fees and costs which are justly due and owing from the Defendant(s) to the Plaintiff. Dated: OCTOBER 13, 2003 ERIC M. BERMAN, P.C. BY: ~ ~ ERIC__S-; ESQUIRE BY: ROBERT M. KLINE ESQUIRE SPACEBN-W-ZN Attorneys for Plaintiff VERIFICATION Eric M. Berman, Esquire, being duly sworn according to law, deposes and says that he is the Principal attorney of Eric M. Berman, P.C., attorneys for the Plaintiff, and/or Robert M. Kline, Esquire, being duly sworn according to law, deposes and says that he is an associate attorney with said firm, and as said attorney, is authorized to take this verification on its behalf, and that the facts in the Complaint as set forth therein are true and correct to the best of his knowledge, information and belief. I verify that the statements made in the within instrument are true and correct. I understand that false statements are subject to the penalties of 18 Pa C.S.A. Section 4904 relating to unsworn falsifications to authorities. ERIC~.B-E~A~'~QUIRE Dated: OCTOBER 13, ~003 ROBERT M. KLINE, ESQUIRE SPACEBNW-ZN SHERIFF'S RETURN CASE NO: 2003-05655 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND - NOT FOUND DISCOVER BANK VS MILLER JAMES H R. Thomas Kline duly sworn according to law, says, that he made a diligent inquiry for the within named DEFENDANT MILLER JAMES H unable to locate Him in his bailiwick. ,Sheriff or Deputy Sheriff, who being search and but was He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT · MILLER JAMES H 521 QUAIL CT MECHANICSBURG, PA 17050-2083 DEFENDANT HAS NOT LIVED AT GIVEN ADDRESS FOR 2 YEARS. HE , NOT FOUND , as to IS BELIEVED TO BE IN A NURSING HOME, LOCATION UNKNOWN. Sheriff's Costs: Docketing 18.00 Service 22.77 Not Found 5.00 Surcharge 10.00 .00 55.77 R. Thomas Kline Sheriff of Cumberland County ERIC BERMAN 11/18/2003 Sworn and subscribed to before me this /q day of ~,~,,,