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Home My WebLink About07-7455 .4 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: 01-- %65 Civil (er,nm vs. MICHELE L HUMMEL COMPLAINT IN CIVIL ACTION Defendant 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 06308996 C A Pit WLG IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No MICHELE L HUMMEL 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: MICHELE L HUMMEL 317 QUEEN ST NORTHUMBERLND, PA 17857 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011298755506981 . 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 November 28, 2007 , in the amount of $4724.46 . 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 $500.00 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 , MICHELE L HUMMEL INDIVIDUALLY , in the amount of $4724.46 with interest at the legal rate of 6.000t per annum from date of judgment plus attorneys' fees of $500.00 , and costs. James Warmbrodt,42524 WELT Jbugh, WEINBERG & REIS CO., L.P.A. 436 th Avenue, Suite 2718 Pitt PA 15219 (41 -7955 F 338-7130 06 0 C A Pit WLG This law firm is a debt collector atteVpting to collect this debt for our client and any information obtained will be used for that purpose. V1a%.r%0v CF. 44,/14.46 144,124.46 I Enter Amount Enclosed Below ? CAnD Payment Due Date $ F October 21, 2007 Please make check payable to Discover Card. Minimumq ent due includes a past due 107 00 amount of $1 22 SDSNGAOt 0008702 ^ O ? . , . k i MICHELE HUMMEL your spend ng Manage your budget, trac id f i h FREE i l d il 317 QUEEN ST l ees w me y e-ma an avo t t reminders. To find out more, visit NORTHUMBERLND PA 17857-1809 Discovercard.com/reminders PO BOX 15251 111 119111111111111111111111111 WILMINGTON DE 19886-5251 Address, e-mail or telephone change? Print change in space above, or go to Discovercard.com. Print your e-mail address to receive important Account information and special offers. 000006011298755506981047244600000000472446 Discover More Card Account Summary Closing Date: September 22, 2007 page 1 of 1 Account number ending in 6981 Previous Balance $4,724.46 Payment Due Date October 21, 2007 Payments And Credits 0.00 Minimum Payment Due $4,724.46 Purchases + 0.00 Credit Limit $5,000.00 Cash Advances + 0.00 Credit Available $0.00 Balance Transfers + 0.00 Cash Credit Limit $0.00 Finance Charges + 0.00 Cash Credit Available $0.00 _ New Balance $4,724.46 Cashback Bonus® Opening Cashback Bonus Balance $ 0.00 New Cashback Bonus Earned + 0.00 Cashback Bonus Balance $ 0.00 Cashback Bonus® Anniversary • Available to Redeem $ 0.00 Date: November 22 How Can We Help You? For Account Inquiries, write to us at Maass have your Discover Card available. Discover More Card, PO Box 30943 Salt Lake City, UT 84130 Manage your account online at Discovercord.com TDD (Telecommunications Device for the Deaf): Customer Service: 1.800-DISCOVER (1.800.347-2683) For assistance, see reverse side. Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence. Information For You While we are permitted under the Cardmember Agreement to increase the APRs on your Account because your payment was late, we have chosen not to do so at this time. We have terminated, however, any introductory or promotional rate on purchases and any special balance transfer rate, and applied the standard APR for purchases to your outstanding balance of purchases and balance transfers. However, we reserve the right to increase the APRs on your Account if you fail to pay the minimum payment due by the payment due date. See the Default Rate P1 ember Agreement for details. BMW Finance Charge Summary Nominal Transaction Average Daily ANNUAL ANNUAL Periodic Fee Daily Periodic PERCENTAGE PERCENTAGE FINANCE FINANCE Balance Rates RATES RATES CHARGES CHARGES current billing period: 31 days Purchases $0 0.07942% 28.99% V 28.99% $0 none Cash Advances $0 0.07942% 28.99% V 28.99% $0 $0 Previous billing period: 22 days Purchases $0 0.07942% 28.99% V 28.99% $0 none The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above. 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 Robert Adkins , (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 # 6308996 MICHELE L HUMMEL 6011298755506981 '"1 0 00 - \ -J CPO ?.... r.? ' TI W C-.- :;7J oo d ; ? rv - 00 ?., .t (71 0 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 07-7455 CIVIL TERM vs. PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE MICHELE L HUMMEL Defendant 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. 1400Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06308996 I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 07-7455 CIVIL TERM MICHELE L HUMMEL Defendant PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR: Settle, Discontinue and End the above-captioned matter upon the records of the Court without prejudice to refile and mark the costs paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: Attorney f 6r Plaintiff 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06308996 SWORN TO AND SUBSCRIBED before me this _-` day of a^ 008 NOT RY PUB e< ?"_ _? ? -_- : ?, - .:?a ''? r --1 ??- . _ C.d _._ :.:_J G';; - ,.