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Home My WebLink About07-7090I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. SCOTT M COOVER Defendant No : 07 -*Yo4d . FOZ.1,7 CoLt 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 06258489 C A Pit WLG D IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No SCOTT M COOVER 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 Rd, New Albany, OH 43054. 2. Defendant is adult individual(s) residing at the address listed below: SCOTT M COOVER 1 NORTHVIEW DR CARLISLE, PA 17013 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011002300673548 . 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 October 31, 2007 , in the amount of $1066.92 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 $100.00 I 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 , SCOTT M COOVER INDIVIDUALLY , in the amount of $1066.92 with interest at the legal rate of 6.000% per annum from date of judgment plus attorneys' fees of $100.00 , and costs. Warmbrodt,42524 WEINBERG & REIS CO., L.P.A. th Avenue, Suite 2718 gh, PA 15219 34-7955 /:12-338-7130 9 C A Pit WLG This law firm is a debt collector of teimpting to collect this debt for our client and any information obt ed will be used for that purpose. ,%W VW • &.1% 51,066.92 CARD $1,066.92 ---' `"` all it rnDerenamg in 3548 Enter Amount Enclosed Belo w Payment Due Date September 14, 2007 Please make check payable to Dis cover Card. Minimum payment due includes a past due amount of $196 00 15 SOSN6A01 0007940 . . SCOTT COOVER 1 NORTHVIEW DR Manage your budget, track your spending and avoid fe i h CARLISLE PA 1701.3-9661 es w t FREE timely e-mail reminders. To find out more visit , Discovercard.com/reminders PO BOX 15251 Address, e-mail or telephone change$ Print change in space WILMINGTON DE 19886-5251 above, or go to Discovercard.com. Print your e-mail address to III1111i11rl1fill If 11/0/1111 I11 11 11111 1111 111 1 receive important Account information and special offers. 000006011002300673548010669200000000106692 Discover More Card Account Summary Closing Date: August 15 2007 Account number ending in 35,48 , page 1 of 1 Payment Due Date September 14, 2007 Minimum Payment Due $1 066 92 Previous Balance Payments And Credits $1'066'92 , . Credit Limit $1,200.00 Credit Available $0 00 Purchases Cash Advances + + 0.00 0.00 . Cash Credit Limit $0.00 Balance Transfers Fina Ch nce + 000 0.00 Cash Credit Available $0.00 arges New Balance + 0 Op $1,066.92 Cashback Bonus® ------- O ---- ---- pening Cashback Bonus Balance New Cashback Bonus Earned $ 0'00 ± X00 Cashback Bonus® Anniversary Cashback Bonus Balance Available to Redeem $ 0.00 Date: August 15 $ 0.00 'How Can We Help You? For Account Inquiries writ t Please have your Discover Cord avagable. , e o us at. 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 TDD (Telecommunications Device for the Deaf); For assistance se , e reverse side. EXHIBIT A- - Finance Charge Summary Average Daily Dail Periodic Nominal ANNUAL PERCENTAGE ANNUAL Periodic Transaction Fe ale a current billing period: 31 d Rates RA RPEA?SNTAGE -- EE e FINANCE ays Purchases $0 Cash Advances $0 0.05477% 19.99% F 19.99% $0 Previous billing period: 15 days 0.0602590 21.99% F 21.99% $0 none $0 Purchases $0 0.05477% 19.99% The rates that apply to your Account are either fixed (F) or the y may vary (v) as n oted above. VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unworn falsifications to authorities, that he/she is (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. ignature) WWR # 6258489 SCOTT M COOVER 6011002300673548 rMr, W w "Ift V C? ? O Min FT.q t "' . T . 111......lll SHERIFF'S RETURN - REGULAR CASE NO: 2007-07090 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS COOVER SCOTT M DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon COOVER SCOTT M the DEFENDANT at 1617:00 HOURS, on the 5th day of December , 2007 at 1 NORTHVIEW DRIVE CARLISLE, PA 17013 by handing to SCOTT COOVER 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 Service Affidavit Surcharge A, ?D _ Sworn and Subscibed to before me this of So Answers: 18.00 4.80 .00 10.00 R. Thomas Kline .00 32.80 12/06/2007 WELTMAN WEINBERG REIS By: day Dep ty Sheriff A.D. f 41 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. SCOTT M COOVER Defendant No. 07-7090 CIVIL TERM PRAECIPE FOR DEFAULT 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 Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06258489 Judgment Amount $ 1166.92 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 07-7090 CIVIL TERM SCOTT M COOVER Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, SCOTT M COOVER above named, in the default of an Answer, in the amount of $1166.92 computed as follows: Amount claimed in Complaint $1,066.92 Interest from date of judgment at the legal interest rate of 6% per annum Attorney's fees $100.00 TOTAL $1166.92 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By: WILLIAM T. MO ZAN, ESQUIRE PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06258489 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 1 NORTHVIEW DR CARLISLE,PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 07-7090 CIVIL TERM SCOTT M COOVER Defendant 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 ?ppg (xx) Assumpsit Judgment in the amount of $1166.92 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 (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary By: PROTH OTARY ) SCOTT M COOVER 1 NORTHVIEW DR CARLISLE,PA 17013 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7t' Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff SCOTT M COOVER Defendant(s) IMPORTANT NOTICE TO: SCOTT M COOVER 1 NORTHVIEW DR CARLISLE,PA 17013 //?? Date of Notice: -09 WWR#: 06258489 Case # Q-7-7690 Ctv lL (610A YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW. 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 REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 BY:?-? R&.Z? ulu1 v voj--- PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Case no: 07-7090 CIVIL TERM Plaintiff VS. SCOTT M COOVER Defendants NON-MILITARY AFFIDAVIT The undersigned, who first being duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. § 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, SCOTT M COOVER is not in the military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the Defendant, SCOTT M COOVER is not in the military service. Further Affiant sayeth naught. / AFFIIAAtN/T SWORN TO AND SUBSCRIBED in my presence this day of Sa O g' NO RY PUBL rv A. J- This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 JAN-11-2008 12:16:37 '< Last Name First/Middle Begin Date Active Duty Status Service/Agency COOVER Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. Ohvt lot 44- Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: http://www.defenselink.mil/faq/pis/PC09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 1/11/2008 Request for Military Status Page 2 of 2 by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID: KHGHJXRXLP https://www.dmde.osd.mil/scra/owa/scra.prc_Select 1/11/2008 z L a N ?o ?h ?i c` ?a f? ?j r J? WELTMAN, WEINBERG & REIS CO., L.P.A. BY: Sarah E. Ehasz, Esquire Attorney for Plaintiff(s) LD. No.86469 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 6258489 DISCOVER BANK Plaintiff vs. SCOTT M COOVER Defendant(s) CUMBERLAND County Court of Common Pleas NO. 07-7090 CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT TO THE PROTHONOTARY: C to . _ 12 3 f', t fv?l. /rj FEB 27 A1110:&5 No COUNTY PENNS YLVAH Please kindly Satisfy the Judgment of the above-captioned matter upon the records of the Court and mark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A. k?- "?? BY <- Sarah E. Ehasz, Esquire Attorney for Plaintiff Sworn to and subscribed Before me the _Z?;, da ARY PU C 2012 COMMONWEALTH OF PENNSYLVANIA_ Notarial Seal Wayne A. ]ones, Notary Public City of Pittsburgh, Allegheny County Poly Commission Expires tune 29, 2014 M-j,L)tar. ?e;Insvivania Association of Notaritt; Qom{ ?% q. SCE P6 all? C1? 163-71 L/Fy VcP