Loading...
HomeMy WebLinkAbout03-6423Our File No. 180683 ATTORNEYS FOR PI~INTIFF ERIC M. BERMAN, P.C. BY: Eric M. Berman, Esquire, I.D. 83898 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 King of Prussia, PA 19406 Va. COURT OF COMMON PLEAS COUNTY OF CUMBERLAND : TRIAL DIVISION 306 : : CIVIL ACTION Term GERALD R BROUGHTON 226 ERFORD RD CAMP HILL, PA 17011 1207 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 Our File No. 180683 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 308 King of Prussia, PA 19406 VS. COURT OF COMMON pLEAS COUNTY OF CUMBERLAND CIVIL ACTION Term No. O~ -- GERALD R BROUGHTON 226 ERFORD RD CAMP HILL, PA 17011 1207 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), GERALD R BROUGHTON , resides at 228 ERFORD RD , CAMP HILL, PA 17011-1207. 3. There is due from the Defendant(s} the sum of $4,413.46 for credit extended by Plaintiff to Defendant(s), acct. no. 6011002793005299, 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 $4,413.46 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 $4,413.46 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./~RMAN, P.C. BY- 'ERIC M. B~UIRE BY: ROBERT M. KLINE ESQUIRE SPACEBNW-ZN Attorneys for Plaintiff VERIFICATION Eric M. Barman, Esquire, being duly sworn according to law, deposes and says that he is the Principal attorney of Eric Mo Barman, 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 o£ 18 Pa CoS°A. Section 4904 relating to unshorn falsifications to authorities. ERIC M. Dated: BERMAN , ESQUIRE OCTOBER 26, 2003 R~T M. KLINE, ESQUIRE SPACEBNW-ZN SHERIFF'S RETURN CASE NO: 2003-06423 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS BROUGHTON GERALD R - REGULAR VALERIE WEARY Cumberland County, Pennsylvania, says, the within COMPLAINT & NOTICE BROUGHTON GERALD R DEFENDANT , at 1039:00 HOURS, at 226 ERFORD RD CAMP HILL, PA 17011-1207 JESSICA BROUGHTON, WIFE a Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 15th day of December , 2003 by handing to true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Service 10.35 Affidavit .00 ~ Surcharge 10.00 R. Thomas Kline .00 38.35 12/16/2003 ERIC BERMAN Sworn and Subscribed to before men,this /~ day of By: y s he r~i~i~f--~