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Home My WebLink About03-6086STOCK & GRIMES, LLP BY: EDW~D STOCK, ESQUIRE I.D.# 13657 804 West Avenue Jenk±ntcwn, PA 19046 (215) 576-1900 AEtoz~ney for Plaintiff DISOOVER B~K, ISSUER OF DISCOVER C~RD BY ITS ~GENT DISCOVER FINANCIAL SERVICES, INC. P.O. BOx 6011 Dover, E~ 19903-6011 Plaintiff D~LE SNYDER 10087 Red Maple Lane Shippensburg, PA 17257-8940 Defendant COURT 0F CONNON PLEAS GivBERL~ND COUNTY C(VIL ACTiON-LAW "NOYICE" "You have been sued in court. If you wish to defend against the ch~inls eel forlh in the fol- lowing pages, you must take action within twenty (20) days slier this con,pistol and ilolice are served, by entering a wlitten appdslanoe person- ally or by attorney artd tiling in writing with the court your defenses or obieclions to the claims se[ Iorth againsl you. You are warned that if you fail to do so the case may proceed without you and a iudgment may be entered against you by the court w~thout further notice for any money claimed in !he complaint or for any other claim or relief requested by the plaintitf. You slay lose money or property or o:her rights m]portant to "YOU SHOULD TAKE TidlS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GD TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU O~N 3ET LEGAL HELF. "AVISO" "Lehan demandado a usteden la corte. Si usted quiere delenderse de estas demandas ex- puestas en las p~ginas siguientes, usted tiene veinte (20) di'as de plazo al psrtir de la fecha de la demands y la notificaci~n. Hace faits asentar ufla comparencla esclita o en persona o COl1 un abogado y entregar a la corte en forma escrita sus defensas osus objeciones a las demandas ell cor~l[D de su persona. Sea avisado que si usted no se defiende, ia corte tomar~ medidas y puede continu[]r ia demands eR contra suya sin prevlo awsoo notificaoion. Ademas, la corte puede decidir a favor del demandante y requiere que usted cumpla con todas las provis¢ones de esta demands. Usted puede perder dinero o sue propiedades u otros derechos importantes para usted." "LLEVE ESTA DEMANDA A UN ABO- GADO Ir,~MEDiATAlvlENTE, Si NO TIENE ABO~ GADO O SI NO TIEI'IE EL DINERO SUFICIENTE DE PAGAn TAL SER~/ICIO¢ VAYA EN PER- SONA O LLAME POn TE.LEFONO A LA CffqA CLW A DIRECCION SE ENCUENTRA ESCRITA ABA JO a, RA AVERIGUAR DONDE SE PUEDE C:ONSE /IR AS!Si ENGI LEGAL. L~WY~R REFERENCE SERVICES Court Adninistrator -- Cumberland Comity Coum-thouse 4th Floor, One Courthouse Square Carlisle, PA 17013 (717) 240-6200 STOCK & GRIMES, LLP BY: EDWARD STOCK, ESQUIRE I.D. #13657 804 West Avenue Jenkintown, PA 19046 (215) 576-1900 Attorney for Plaintiff DISCOVER BANK, ISSUER OF DISCOVER CARD, BY ITS AGENT DISCOVER FINANCIAL SERVICES, INC. P.O. Box 6011 Dover, DE 19903~6011 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION-LAW - VS. DALE SNYDER 10087 Red Maple Lane Shippensburg, PA 17257-8940 Defendant(s) CIVIL ACTION COMPLAINT IN ASSUMPSIT 1. Plaimiff, Discover Bank, issuer of Discover Card, by its agent Discover Financial Services, Inc., is a duly' organized banking institution under the laws of the State of Delaware and has a principal place of business at the address contained in the above caption. 2. Defendant(s), Dale Snyder, is an adult individual and resides at the address contained in the above caption. 3. After application by the Defendant(s) to the Plaintiff for a credit card account, which application was approved by the Plaintiff, the Plaintiff issued a credit card to the Defendant(s) so that the Defendant(s) could make purchases from merchants, on credit, who had established a business relationship with the Plaintiff in regard to the same. 4. Thereafter, the Defendant(s) utilized the said credit card on various and sundry occasions. 5. Plaintiff attaches hereto as Exhibit "A" to this Complaint, a true and correct copy of the last monthly statement in regard to the activities in connection with the Defendant's account and also attaches hereto as Exhibit "B" to this Complaint, an Affidavit from the Plaintiff attesting to the present balance due the Plaintiff from the Defendant(s) in regard to the said account. 6. Notwithstanding repeated requests and demands to the Plaintiff upon the Defendant(s) to satisfy the outstanding indebtedness in the sum of $13,922.71 the Defendant(s) has/have and still refuse(s) to pay the same. 7. As a result thereof, Plaintiff has been forced to incur reasonable attorney collection fees in the sum of $3,480.67 in an attempt to legally enforce collection of the debt due it from the Defendant(s), which reasonable attorney fees are the responsibility of the Defendant(s) to pay in accordance with the Card Agreement. 8. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY iNFORMATION OBTAiNED WILL BE USED FOR THAT PURPOSE. WHEREFORE, Plaintiff, Discover Bank, issuer of Discover Card, by its agent Discover Financial Services, Inc., demands Judgment against the Defendant(s), Dale Snyder, in the sum of $17,403.38, with interest and costs. Attorney for Plaintiff VERIFICATION EDWARD STOCK, ESQUIRE, Attorney for Plaintiff herein, verifies that the statements made in this Pleading are true and correct and that he is authorized to make them on behalf of the Plaintiff. He understands that the statements herein are made subject to the penalties of 19 Pa. C.S.A. Sec. 4904, relating to unsworn falsification to authorities. CREDIT '$TATE~4ENT IS ON HOLD '~'~-IN ~ DATE: DATE: 07/;~7/0 BALANCE TRANSFERS ¢. FINANCE CHARGES: -,- iqEW BALANCE: -: AND CREDTT$ (' O,/]L$ PAYMENT ?HAN~:. YOd 1,'q-3 22.71 200~ 00 0.00 O, 00 F9-PAEM Fi0-NEXT F~-'v'IEW DETAIL IHSG: LAST PAGE OF THE 'STATEMENT F7-UP FZ4-AD~ FJ.S-REPRZNT E~{IBIT "¥' ATTORNEY: ACCOUNT NUMBER: BALANCE: CARDMEMBER (S),: STOCK 6011002733002356 $14322.7l DALE SNYDER STATE OF OHIO COUNTY OF FRANKLIN C. Ball, personally appeared before me, this day and after being duly swom, according to law, upon his/her oath and :says: I am a Legal Placement Account Manager for DISCOVER FINANCIAL SERVICES INC., the servicing agent of DISCOVER BANK, an FDIC insured Delaware State Bank. THAT this affidavit is made on the basis of my personal knowledge and in support of Plaintiff's suit on account against: the Debtor(s) THAT, in my capacity as Legal Placement Account Manager, I have control over and access to records regarding the Discover Card Account of the above referenced Debtor(s), further, that I have personally inspected said Account and statements regarding the balance due on said account. DISCOVER FINANCIAL SERVICES, INC. maintains these records in the ordinary course of business. THAT the annexed statement of account is a true and correct statement of what is now due and owing Discover Bank on the account, and exhibit A is a copy of the Cardmember Agreement between Discover Bank and the above referenced Debtor(s). The Cardmember Agreement governs the terms and conditions of the relationship between Discover Bank and the Debtor(s) in connection with the account. Based on my review of the account records, to the best of my knowledge and belief the above referenced Debtor(s) is not engaged in the military service of the United States and is a resident of the State and of the Coantry in which this action has been filed. 1 declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. Affiant Sworn and Subscribed before me, This day of Tuesday, April 08, 2003. EXHIBIT "B" STOCK & GRIMES, LLP BY: Edward Stock, Esquire I.D. #13657 804 West Avenue Jenkintown, PA 19046 (215) 576-1900 Attorney for Plaintif DISCOVER BANK, ISSUER OF DISCOVER CARD BY ITS AGENT DISCOVER FINANCIAL SERVICES, INC. P.O. Box 6011 Dover, DE 19903-6011 Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION-LAW NO. 2003-06086 vs. DALE SNYDER 10087 Red Maple Lane Shippensburg, PA 17257-8940 Defendant(s) PRAECIPE TO DISCONTINI~ TO THE PROTHONOTARY: DATE: Kindly mark the above captioned c~/~ued.