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Home My WebLink About03-6090IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. RYAN WENGER Defendant COMPLAINT IN CIVIL ACTION 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#03226067 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. RYAN WENGER Defendant Civil Action No. COMPLAINT IN CIVIL ACTION 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 LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 COMPLAINT Plaintiff is a corporation with offices at 3311 Mill Meadow Drive, Hilliard, OH 43026. 2. Defendant is an adult individual residing at 612 N. 2nd Street, Wormleysburg, PA 17043. 3. Defendant applied for and received a credit card issued by Plaintiff's bearing the account number 6011-0026-4067-0857. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of September 17, 2003, in the amount of $4,048.24, as shown by Plaintiff's Statement of Account attached hereto, marked as Exhibit "1" and made a part hereof. 5. Defendant is in default of the terms of the cardholder Agreement having not made monthly payments to Plaintiff thereby rendering the entire balance immediately due and payable. 6. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, finance charges or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, Ryan Wenger individually, in the amount of $4,048.24 with interest at the legal interest rate of 6% per annum from date of judgment plus costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR TitAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. William T. Molczan,,,R~quire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#:03226067 E)ISCC VER Oclobe~' 16, 2003 C A R D minimum peyment due $603.00 h.,llh.,llh,.h,h,lh,,,lllh,,Ih,,.hl,.hll 84 SDCNSA01 0001760 RYAN WENGER 612 N 2ND ST NnRHLEYSBURG PA 170q3-100Z $4,048.24 6JrnplJfy and Savel Use your DIscove~ Card to pay off high-rate [3alallCeS today. YOU call save money and consolidateyour debt into one =onvenlent paymm~t. Call 1-877-353-0941 to see If a special Balance Transfer otter is available for you. PO Box [szst IIh,,Ih,,,,,llh,,h,hll t,/]:LHTNi}TON DE 19886-525]. h.llhh,h,hh,h,lh,,hh,.hhhh,.Ihhh.,llhh,I 000006011002640670857040482400000000060300 Discover Card Account Summary Closing Date: September 17, 2003 page 1 of 2 acceuntnumber 60'[ 1 0026 4067 0857 previous balance $3,916.87 payment due date October 16, 2003 payments and credits 0.00 minimumpaymentdue $603,00 purchases .I. 64.00 credit limit $3,000.00 cash advances + 0.00 credit available $0,00 cash credit lirblt $1,500.00 balance transfers + 0.00 cash credit available $0.00 FINANCE CHARGES + 67.37 new balance = $4,048.24 You may be able te avoid Periodic Finance Charges, see the reverse side for details. SPECIAL BALANCE TRANSFER RATESI Save money and simplify your life by consolidating your debt, Call 1-800-767-7339 today to see if an offer is available for youl Transactions trans, post date date Other/Miscellaneous Sep 17 Sep'17 OVERLIMIT FEE $ 29,00 Sep 17 Sep 17 LATE FEE 35,00 ~implify and Savel Use your Discover(R) Card to pay off high-rets balances today. You can save money and consolidate your debt into one convenient payment. Call 1-877-353-0985 to see ifa Balance Transfer offer is available tor you. IVow you can use your Discever~R) Card at over 500 Bob Evans tocationsl You can enjoy Bob Evans homestyle flavors i~ ~ their ldtchen or yours for breakfast, lunch or dinner. Take the time to enjoy a heallland tradition. Come home to Bob t~ vans and use your Discover Card. ~saDis~ve~(R)~ar~mern~r~ang~t~ash~uick~y~deasi~y--justab~utanytirne~anywhere~ To,i d the ne est EXHIBIT ~ash locations, select your P.I.N., or to order Discover Card Cash Checks, call I~900~DISCO VER (I-800~34 7-2683). And don'r forge! to visit us a t Discovercard. corn where you can a/so sea,ch for cash locations nearest you. Nominal Transaction Average Daily ANNUAL ANNUAL Periodic Fee Da!ly Periodic PERCENTAGE PERCENTAGE FINANCE FINANCE Balances Rates RATES RATES CHARGES CHARGES ~;urmnt billing period: 31 days Purchases $3831.68 0.05477% 19.99% F 19.99% $65.07 none CARD RYAN WENG~'R account number: 60i 1 ~02640670857 Cashback Bonus ® Award Summary Cashback Bonus Anniversary Date: Jul)/17 Previous Cashback Bonus Award Balance Traditional Award This Period Cashback Bonus Award Total Cashback Bonus Award Balance Award Available to Redeem Balance $ 0.o0 + 0.o0 0.00 0,00 $ 0.0o VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unswom falsifications to authorities, that he/she is (Name) Accounts Manager of Discover Financial Services Inc., servicing agent of the plaintiffherein, that (Title) (Company) he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Complaint are tree and correct to the best of his/her knowledge, information and belief. (Signamre) SHERIFF'S RETURN CASE NO: 2003-06090 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK WENGER RYAN VS - REGULAR GERALD WORTHINGTON Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon WENGER RYAN DEFENDANT , at 1750:00 HOURS, at 612 N 2ND STREET WORMLYEYSBURG, PA 17043 RYAN WENGER a true the on the 26th day of November , 2003 by handing to and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.35 Affidavit .00 Surcharge 10.00 .00 38.35 Sworn and Subscribed to before me this /0~ day of ~~ ~ A.D. / Prothonotary So Answers: ~EI,TMNAN ~ETN~E~ R~TS Deputy Sh~i f f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. RYAN WENGER Defendant No, 03 6090 PRAECIPE TO SETTLE, DISCONTINUE & END 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#03226067 1N THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 03 6090 RYAN WENGER Defendant PRAECIPE TO SETTLE DISCONTINUE AND END TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue and End the above captioned matter upon the records of the Court and mark the cost paid. Sworn to and subs~r'b~ Before me the ~ Day of~ NOTzt~RY PI},BL. tC' ~ WELTMAN, WEINBERG & REIS CO., L.P.A. pW iA 1.1ii~.. #~5 -4M~¢ c z an: l~s quir~ WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03226067