HomeMy WebLinkAbout03-6239'])ur File Yo.
ATTOi-d~EYS FOR PT~%INTIFF
EF~ C M. BERMAN
Fl: Eric M. Berman, Esquire, I.D. 63698
~ff: 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. BEGAN,
198 Allendale Road, Suite 306
King of Prussia, PA 19406
COURT OF COMMON PLEAS
COUNTY OF CUMBERLAND
TRIAL DIVISION
CIVIL ACTION
Term
BRIAN WALTERS
76 SPRING (]ARDEN EST
CARLISLE, PA 17013 7105
No.03
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 ~}UR LAWYER AT ONCE. IF YOU DO
NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFIOE
SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL BELP. 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 (DR NO FEE.
LAWYER REFERENCE SERVICE
COUNTY OF CUMBERLAND BAR ASSOCIATION
2 LIBERTY AVE.
CARLISLE, PA 17013
800-990-9108
, [~ur File No. 169368
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 3<)6
King of Prussia, PA 19406
(glO) 285-7720
DISCOVER BANK
c/o ERIC M. BERMAN, P.C.
198 Allendale Road, Suite 306
King o£ Prussia, PA 19406
VS.
COURT OF COMMON PLEAS
COUNTY OF CUMBERLAND
CIVIL ACTION
Term
No.
BRIAN WALTERS
76 SPRING GARDEN EST
CARLISLE, PA 17013 7105
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), BRIAN WALTERS ,
resides at 76 SPRING GARDEN EST , CARLISLE, PA 17013-7105.
3. There is due from the Defendant(s) the sum of $1,160.01 for
credit extended by Plaintiff to Defendant(s), acct. no. 6011002909531113,
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 $1,160.01 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.
6. All applicable credits, if any, have been duly applied to
Defendant(s) credit account.
WHEREFORE, Plaintiff claims of the Defendant(s) the sum of $1,
plus interest, attorneys fees and costs which are justly due and
owing from the Defendant(s) to the Plaintiff.
Dated: OCTOBER 17, 2003
ERIC M. B '. '.
BY: E~
ERIC~N, ESQUIRE
BY:
~DBERT M. KLINE ESQUIRE
SPACEBNW-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, PoC., 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 M. BERMAN, ESQUIRE ROBERT M. KLINE,
Dated: OCTOBER 17, 2003
E SQU I RE
SPACEBNW-ZN
SHERIFF'S RETURN
CASE NO: 2003-06239 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAiqD
DISCOVER BANK
WALTERS BRIAN
VS
REGULAR
ROBERT BITNER
Cumberland County, Pennsylvania,
says, the within NOTICE
WALTERS BRIAN
DEFENDANT , at 0020:49 HOURS,
at 76 SPRING GARDEN EST
CARLISLE, PA 17013
JENNIFER WALTERS (WIFB)
a true and attested copy of NOTICE
COMPLAINT
Sheriff or Deputy Sheriff of
who being duly sworn according to law,
was served upon
the
on the 3rd day of December , 2003
by handing to
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 3.45
Affidavit .00
Surcharge 10.00
.00
31.45
Sworn and Subscribed to before
me this /~ day of
k~ JO~k3 A.D.
/ ~rothonotary
So Answers:
R. Thomas Kline
12/04/2003
ERIC BERMAN
)Deputy Sherlrz
~,e.~m,:..n, l~aqulre, I.D. 83698
t(.irie, Esquire,I.D. 56479
OURi OF ~OMMON PLEAS
........................................ X COUNTY OF CUMBERLAND
P : TRIAl, DIVISION
Road, Suite 212
['russia, PA 19,106 : CIVIL ACTION
No. 2003-06259
N,.TIbE ,..F INTENTION TCI TAKE DEFAvL~ ,~ 3L~MEN~
TO: B~:iAN WALTERS
76 o=~= ~ARDEN EST
CARL~oLE, PA
DATE OF NGT~CE:
iMPO~ANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAItLED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE
COURT YOUR DEFENSES OR OBJECTION.~ TO ~HE CLAIMS SET FORTH AGAINST
YOU. UNLESS YOU ACT WITHIN TEN'DAYS FROM THE DATE OF THiS NOTICE,
A JUDGMENT MAY BE ENTERED A~AINST YOU WITHOUT A HEARING AND YOU
MAY LOSF. YOUR PROPERTY OR OTHER. iMPOR~I'ANT RIGHTS.
YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU
~) NOT HAUE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH
BELOW. THIS OFFICE (]AN PROVIDE YOU WITH INFORMATION ABOUT HIRING
A LAWYER.
IF YOU CANNOT AFFORFD TO HIRE A LAWYER, THIS OFFICE MAY BE
ABLE TO PROVIDE YOU WITH INFORMATION ~BOUT AGENCIES THAT MAY OFFER
LEGAL SERVIC, ES TO ELIGIBLE PERSONS AT A~ REDUCED FEE OB' NC) FEE.
COUNTY OF ~I)MBERLAND BAR ASSOCIATION
2 LIBERTY AVE.
CARLISLE, PA 17013
B00-990-9108
ERIC M. BERMAN, P.C.
Attorneys for Plainti'ff
By: Eric M. Be[man, Esquire
ERIC M. BERMAN, P,£:.
"Attorneys for Plaintiff
By: Robert M. Kline, Esquire
~,[ACEJUI -,,H