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HomeMy WebLinkAbout03-6240ATTO?SE>P8 ?DF' F'L£,iXTfFF Ernc M. Berman. Esquire, I.D. 88698 Roberh M_ Kiine, XsauiPe~I.I). 56479 Ai!endale Road: Suite 806 King of Prussia, PA 19406 (glO) 265-7720 DISCOVER BANK ~/o ERiC M. BERMAN~ P.C. 198 Allendale Road, Suite 806 King of Prussi~, PA i~406 COURT OF COMMON PLEAS COUNTY OF (~MBERLAND TRIAL DIVISION CIVIL ACTION MEEN A SINGH 225 WOOD ST CAMP HILL, PA 17011 2640 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 YOUR LAWYER AT ONCE. IF YOU NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFIC, E SET FORTH BEI~DW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. 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 REFERENCE SERVICE COUNTY OF CUMBERLAND BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PA 17018 800-990-9108 O~r Pile No. 156599 ATTORNEYS ~DR PLAINTIFF ERIG M. BERMAN, P.C. BY: Eric M. Berman, Esquire, I.D. 83696 BY: Robert M. Klins, Esquire,I.D. 58479 198 Allendale Read, Suite 306 King of Prussia, PA 19406 (810) 265-7720 DISOOVER BANK c/o ERIC M. BERMAN, P.C. 198 Allsndale Road, Suite 306 King of Prussia, PA 19406 COURT OF COMMON PLEAS COUNTY OF G3MBEILLAND CIVIL ACTION Term : No. MEEN A SINGH 225 ~30D ST CAMP HILL, PA 17011 2640 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. Tbs Defendant(s) MEEN A SIN.~H , resides at 2~5 WOOD ST , C:AMP HILL, PA 17011-2640. 3. There is due from the Defendant(s) the sum of $11,489.03 for credit extended by Plaintiff to Defendant(s), acct. no. 6011002260295316, and ~]ich 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 $11,489_03 advanced to Defendant(s) throu~] 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. 5. Ail applicable credits, if any, have been duly applied to Defendant(s) credit account. WHEREFORE, Plaintiff claims of the Defendant(s) the sum of $11,489.03 plus interest, attorneys fees and costs which are justly due and owing from the Defendant(s) to the Plaintiff. Dated: OCTOBER 17, 200:3 ERIC M. BEGAN, P.C. BY: ~t/t/x~/~ ~ ERIC M~AN, ESQUIRE BY: ROBERT 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, P.C., 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, ESQUIRE Dated: OCTOBER 17, 2003 SPACEBNW-ZN SHERIFF'S RETURN - CASE NO: 2003-06240 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND NOT FOUND DISCOVER BANK VS SINGH MEEN A R. Thomas Kline duly sworn according to law, inquiry for the within named DEFENDANT SINGH MEEN A unable to locate Him in his bailiwick. ,Sheriff or Deputy Sheriff, who being says, that he made a diligent search and but was He therefore returns the COMPLAINT & NOTICE the within named DEFENDANT , SINGH MEEN A , NOT FOUND as to 225 WOOD ST CAMP HILL, PA 17011 NOT AT 225 WOOD STREET CAMP HILL. 3411 HAWTHORNE DR CAMP HILL. FORWARDING AT PO IS HE IS NOT THERE EITHER. Sheriff's Costs: Docketing 18.00 Service 10.35 Not Found 5.00 Surcharge 10.00 .00 43.35 So answers: ..... ~-~ f~ ~-.--~/~ ~._~~ / R. Thomas Kli~[e Sheriff of Cumberland County ERIC BERMAN 12/11/2003 Sworn and subscribed to before me this /~ t~ day