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