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Home My WebLink About03-6241Our File No. 180463 ATTORNEYS FOR PLAINTIFF ER~C M. BERMAN, P.C. BY: Eric M. Berman, Esquire, I.D. 83698 BY: 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. BERMAN, P.C. 198 Allendale Road, Suite 306 King of Prussia, PA 19406 COURT OF COMMON PLEAS COUNTY OF CUMBERLAND TRIAL DIVISION : CIVIL ACTION : Term CHARLOTTE E BOWMAN 53 SAMPLE BRIDGE RD MECHANICSBURG, PA 17050 2386 No. OZ 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 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. 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 17013 800-990-9108 Out'File No. 180463 '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 306 King of Prussia, PA 19406 (610) 265-7720 DISCOVER BANK c/o ERIC M. BERMAN, P.C. 198 Allendale Road, Suite 306 King of Prussia, PA 19406 VS. COURT OF COMMON PLEAS COUNTY OF CUMBERLAND CIVIL ACTION Term : : No. CHARLOTTE E BOWMAN 53 SAMPLE BRIDGE RD MECHANICSBURG, PA 17050 2386 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, MILLIARD, OH 43026. 2. The Defendant(s), CHARLOTTE E BOWMAN , resides at 53 SAMPLE BRIDGE RD , MECHANICSBURG, PA 17050-2386. 3. There is due from the Defendant(s) the sum of $1,536.93 for credit extended by Plaintiff to Defendant(s), acct. no. 6011001036519413, 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 $1,536.93 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. 5. All applicable credits, if any, have been duly applied to Defendant(s) credit account. WHEREFORE, Plaintiff claims of the Defendant(s) the sum of $1,536.93 plus interest, attorneys fees and costs which are justly due and owing from the Defendant(s) to the Plaintiff. Dated: OCTOBER 26, 2003 ERIC M~~, P.C. BY: 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 thio 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 Dated: OCTOBER 26, 2003 ROBERT M. KLINE, ESQUIRE SPACEBNW-ZN SHERIFFIS RETURN CASE NO: 2003-06241 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS BOWMAN CHARLOTTE E REGULAR VALERIE WEARY , Cumberland County, Pennsylvania, Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the 9th day of December , by handing to together with says, the within COMPLAINT & NOTICE BOWNhAN CHARLOTTE E DEFENDANT at 1516:00 HOURS, on the at 53 SAMPLE BRIDGE RD MECHA/qICSBURG, PA 17050 CHARLOTTE E BOWMAN a true and attested copy of COMPLAINT & NOTICE 2003 and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 6.90 Affidavit .00 Surcharge 10.00 .00 34.90 Sworn and Subscribed to before me ~his ~ day of ~?~~t~On4~t a ry~ So Answers: R. Thomas Kline 12/10/2003 ERIC BERMAN By: 01~~ File No. 18)463 7+TTORNEYS FOR PLAINTIFF BY: Eric M. ~rman, Esquire, I.D. 83698 BY: Robert M. Kline, Esquire. I.D~ 56~79 198 Allendale Road, Suite King of Prussia, PA 19406, (610) 2~5-7720 COURT OF COMMON PLEAS COUNTY OF CUMBER. LAND DISCOVER BANK c/o ERIC M~ BERMAN, 198 Allendale Road, Suite 306 King of Prussia, PA 19406 CHARLOTTE E BOWMAN TF'IAL ~)! VI=,~og ~ l L ACTION PRAECIPE TO ENTER DEFAULT JUDGemENT TO THE PROTHONOTARY: Please enter a default judgment in favor of Plaintiff, DISCOVER BANK and against Defendant,, CHARLOTTE E BOWMAN for failu~'e to answelTM or othe~wise Pespond to the Complaint - Civil Action. The Complaint was served upon Defendant on 12/09/2003, by the Sheriff's ¢ '~ "~ Dffz~ of ~DUNTY OF CUMBERLAND County. A copy of the Notice of Intention to Take [.,efault served upon the Defendant by regular mail on~] is attached hereto as Exhibit B. I certify that written notice of the intention ~o file 5his Praeci was mailed or delivered to the party against whom judgment is to be entered after the default occurred and at least ten days prior to the date of the filing of this Praecipe. Copies are attached~ the amount demanded in the Complaist, and oourt costs. ERIC M. BERMAN, P.C. Attorneys for Plaintiff By: Eric M. Berman, Esquire in the pr~ncipai amount of $1,536.~L~, being together with attorneys fees ERIC M. BERMAN~ P.C. Attorneys for Plaintiff By: Robert M. Kline, Esquire SPACEJUB-ZH TO: I?~PORTANT :~ .. ~ I,..r~ YOU AHE iN iEFAiJLT BECAUSE YOU HAVE FA!iLED TO ENTER :~ WfFiTEi~ APPEARANCE PERS,2,~q~LLY )R BY ATTORNEY AND FILE iN WRiTiN.~ WIT':{ TEE -2OL}RT YOOR DEFENSES )R O~JECTION:{, TO ?HE Chala~S SET FOR'rk ASAiNST T'SL~. ONLESS YOU ACT WllJHIN TEN DAYS FROPf THE DATE OF THiS NO'I'N)E, A O;.~D<~IENT ~{AY ~E ENTERED AGAINST YOJ WITHO[JT A HERRING ANL YOU SAY LOSE 'fOUR PNOPER:TY OR OTHER [~'iPORTANT RiG~iTS. YOU SHOIJLD TAKE THiS NOTICE TO YOUR LAWYER AT O~.:CE. NOT HAVE A LAWYER., ,20 T:> OR TELEPHONE THE OFFICE SET BEL/,W. Ti{iS ,;>YPICE <;AN PR?VIDE YOLI WiTH iNFORKATiON ABO[T LAWi ~ur File No. 180463 ATTORNEYS FOR PLAINTIFF ERIC M. BERMAN, P.C. By: Eric M. Berman, Esquire, I~D. By: Robert M. Kline, Esquire,I.D. 198 Allendale Road, Suite 306 King of Prussia, PA 19406 (610) 265-7720 8369 5647 DISCOVER BANK c/o ERIC M. BERMAN, P.C. : 198 Aliendale Road, Suite 306 : King of Prussia, PA 19406 : vs. : No. 2003-06241 CHARLOTTE E BOWMAN COURT OF COMMON PLEAS COUNTY OF CUMBERLAND TRIAL DIVIS!C,N CIVIL ACTION CERTIFICATION OF NON-MILITARY SERVICE I am one of Plaintiff's attorneys and am authorized to make this certification on Plaintiff's behalf. The above named Defendant(s) is (are) over lib years of age and reside at 53 SAMPLE BRIDGE RD , MECHANICSBURG, PA 17050 2386. The occupation of the Defendant(s) is (are) unknown. The r~fendant<s} is (are) not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto. I verify that the statements made in the foregoing certification are true and correct to the best of my knowledge~ information end belief, and I understand that the statements in said certification are made subject to the penalties of Pa.C~S. 4904 relating to unsworn falsification to authorities. ERIC M. BERMAN, ESQUIRE ATTORNEY FOR PLAINTIFF SPACEJUB-ZE ROBERT M. K ESQ~ .iRE ATTORNEY FOR PLAINTIFF ;ur File No. ATTORNEYS FOR PLAINTIFF ERIC M. BERMAN, BY: ~ric M. Berlnan, Esquires I.D. BY: Robert M. Kline, Esquire. I.D. i~8 Ailendale Road, Suite King of Prussia~ PA 19406 ~610) 285-7720 8369 564? DISCOVER BANK c/o ERIu, M. BERMAN, P.C. : 198 Allendate Road, Suite 306 King of Prussia, PA 19406 CHARLOTTE E BOWMAN tA)URT {DF COMMON PLEAS COUNTY (IF u,~MBERbAND T~:iAL DIViSiON CIVIL ACTION CERTIFICATION OF ADDRESSES TO THE PROTHONOTARY: _ The address of the Plaintiff, Judgment Creditor, is c/o Eric M. Berman, P.O., 198 Allendale Road, Suite 306, Eing of Prussia, PA 19406. The last known address of the Defendant, Judgment Debtor, 53 SAMPLE BRIdlE RD , MEC~ANIO~BURG, PA 17050 2386. Eric M. ~e*rman, Attorneys for Plaintiff By: Eric M. Berman, Esqu&re SPA CEJ UB- ZH Eric M. Ber]~an, l'.C. Attorneys for Plaintiff By: Robert M. KlJne, Esquire ~ur File No. 180463 ~TTOPI~EYS FOR PLAINTIFF ERJC M. BEPfiqAN, By: Eric M. Berman:. Esquire, I.I). 83698 By: Robert M. Kiine, Esquire,I.D. 56479 29~ Ailendale Road, Suite 306 King of Prussia, PA 19406 {6t0) 265-7720 DISCOVER BANK c/o ERIC M. BERMAN, 198 Allendate Road, Suite 306 : King of Prussia, PA 19406 : vs. : No. 2003-06241 ~HARLcTTE E BOW~,AN COURT OF COMMON PLEAS COUNTY OF ~,JMBERLAND TRIAL DIVISION ~,IVIL ACTION TO: CHARLOTTE E BOWMAN 53 SAMPLE BRIDGE RD MEC, HAN I ~.oBURG, PA 17050-2386 P~u~ to Rule 236 o~, the S~re~Oouk% of Pennsylvani}, you are ~by~otified that a ~ME~ BY{~EF~0~T bas been entered -- ~ain~' you in the above~o~din~and that enclosed herewith is a ~ ~ all ~he (~eoord) dOc~n%s~le~ in support of the said IF YO¢~AV~ ANY QUEoTIO~NCERNINC~ TH~, NOTICE, P~E .,ALL: E~ g:2 B~AN, P.C., atto~ys at ~w.'~ Attention: Eric M. Berman, Esquire,~, or-~berto, M. Kline, Esqui~ ~ at this telephone number. 1-6~0-265-77~0. PROTHON DTqRY