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Home My WebLink About03-6424Our File No. 180994 ATTORNEYS FOR PLAINTIFF ERIC M. BERMAN, P.C. BY: Eric M. Berman, Esquire, I.D. 83698 BY: Robert M. Eline, Esquire,I.D. 56479 198 Allendale Road, Suite 306 Sing 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 TRIAL DIVISION : CIVIL ACTION Term TUYEN Q LE 1023 DREXEL HILLS BLVD NEW CUMBERLND, PA 17070 1737 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 'CHIS 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 Fils No. 180994 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 COURT OF COMMON PLEAS COUNTY OF CUMBERLAND CIVIL ACTION Term TUYEN Q LE 1023 DREXEL HILLS BLVD NEW CUMBERLND, PA 17070 1737 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 8311 MILL MEADOW DRIVE, HILLIARD, OH 43026. 2. The Defendant(s), TUYEN Q LE , resides at 1023 DREXEL HILLS BLVD , NEW CUMBERLND, PA 17070-1737. 3. There is due from the Defendant(s} the sum of $8,236.13 for credit extended by Plaintiff to Defendant(s), acct. no. 6011002150672251, 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 $8,236.13 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. Wq4F_~FORE, Plaintiff claims of the Defendant(s) the sum of $8,238.13 plus interest, attorneys fees and costs which are justly due and owing from the Defendant(s) to the Plaintiff. Dated: OCTOBER 26, 2003 ERIC Mo B~AN, P.C. BY: / ERIC M. BE~UIRE 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 Dated: OCTOBER 26, 2003 ROBERT M. KLINE, ESQUIRE SPACEBNW-ZN SHERIFF'S RETURN - CASE NO: 2003-06424 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK LE TUYEN Q VS REGULAR BRIAN BARRICK , Cumberland County, Pennsylvania, says, the within COMPLAINT & NOTICE LE TUYEN Q DEFENDANT at 1810:00 HOURS, on the at 1023 DREXEL HILLS BLVD NEW CUMBERLAND, PA 17070 BACH LE, SISTER, a true and attested copy of COMPLAINT & NOTICE Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the 2nd day of January 2004 by handing ADULT IN CHARGE tO together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 23.46 Affidavit .00 Surcharge 10.00 .00 51.46 Sworn and Subscribed to before me this ~- day of A.D. ~r/othonotary '~ So Answers: R. Thomas Kline Ol/O5/2oo4 ~ ERIC BERMAN ~ Deputy Sheriff Our File No. 180994 ATTORNEYS ~DR PLAINTIFF ERIC M. BERMAN, P oC. ~Y: Eric M. Berman, Esquire, I.D. 53698 BY: Robert M. Kline, Esquire.I.D. 56479 198 Allendale Road, Suite 306 King of Prussia, PA 19406 (610} 265-7720 COURT OF COMMON PLEAS COUNTY OF CUMBERLAND DISCOVER BANK c/o ERIC M. BEPMAN, P.C. 198 Allendale Road, Suite King of Prussia, PA 19406 306 *CS. TRIAL DIVISION CIVIL ACTION No. 2003-06424 TUYEN Q LE PRAECIPE TO ENTER DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter a default judgment in favor of Plaintiff, DISCOVER BANK , and against Defendant, TUYEN Q LE for failure to answer or otherwise respgnd to the Complaint - Action. Civil The Complaint was served upon Defendant on 01/02/2004, by the Sheriff°s Office of COUNTY OF CUMBERLAND County. A copy of the Notice of Inte~ion to Take Default served upon the Defendant by regular mail on -~%~ ~ 2k~o~ is attached hereto as E×hibit B. - ~- r~ ,/ I certify that written notice of the intention to file this Praec 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. R.C.P.~ Assess damages in the principal the amount demanded in the Complaint, and court costs. ERIC M. BERMAN, P.C. Attorneys for Plaintiff By: Eric M. Berman, Esquire 9* ~ amount of $8,-36.i~, being together with attorneys fees ERIC M. BERM&N, P.C. Attorneys for Plaintiff By: Robert M. Kline, Esquire SPACEJUB- ZH ~rman, Esquire~ !.Eh S369 ~, Kline, Esquire,I D~ 5647 ~.~ Road~ Suite 306 t~Ya, PA 19406 ~ANK BERMAN, P... ~lIendale Road, Suite 306 Prussia, PA 19406 LE COURT OF COMMON PLEAS COUNTY OF CUMBERLAND TRIAL DIVISION CIVIL ACTION No. 2003-06424 CERTIFICATION OF NON-MILITARY SERVICE I sm one of Plaintiff's attorneys and am authorized to make certification on Plaintiff's behalf. The above named Defendant(s) is (are) over 18 years of age ~d reside at 1023 DREXEL HILLS BLVD , NEW CUMBERLND, PA 17070 1737 The occupation of the Defendant(s) is (are) unknown. The Defendant(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 certifica~ are true and correct to the best of my knowledge, information and belief~ and I understand that the statements in said certificatio are made subject to the penalties of Pa.C~S. 4904 relating to unsworn falsification to authorities. ERIC M. /~ ~AN, ESQUIRE ATTORNEY FOR PLAINTIFF SPACEJUB-ZK ROBERT M. KLINE, ESQUIRE ATTORNEY FOR PLAINTIFF Our File No. 180994 ATTORNEYS FOR PIJtINTIFF ERIC M. BERMAN, P.C. BY: Eric M. Berman, Esquire, I.D. ~',869 BY: Robert M. Kline, Esquire. I.D- 5647 198 Allendale Road, Suite 806 Xing of Prussia, PA 19406 (6i0) 265-7720 DISCOVER BANK c/o ERIC M. BEGAN, P.C. 198 Allendale Road, Suite 306 King of Prussia, PA 19406 TUYEN Q LE COURT OF COMMON PLEAS COUNTY OF CUMBERLAND TRIAL DIVISION CIVIL ACTION No. 2003-06424 CERTIFICATION OF ADDRESSES TO THE PROTHONOTARY: The address of the Plaintiff, Jud~nent Creditor, ~u~te 30~, Erie M. Berman, P.C., 198 Allendal~ Road, Prussia, PA K~ns of The last ]~nown address of the Defendant, Judgment Debtor, is 10~o DREXEL HILLS BLVD NEW CUMBERLND, PA 17070 1,~7. E?'ic M. Berman, P.C. Attorneys for Plaintiff By: Eric M. Berman, Esquire oPA CEJ UP,- ZH Eric M. Berman, P.C. Attorneys for Plaintiff By: Robert, M. Kline, Esquire t~ · M. BERMAN? P.C. By: Erlc h. Berman, Esquire, I.D. 8,~,b98 By: Robert M. [[line, Esquire,I.D. o~,479 1 ....Allendale B_ad. .~u~te King of Pru~sia, PA 19406 (~0~ 265-7720 DIoCJVER BAbK ' ~ !'.C. : TRIAL DIVISION c/o ERIu M, BEGAN, 1~,8 Allendale R~,ad, oulte o{.)6 : CIVIL ACTION King of Prusaia. PA 19406 : vs. : No. 2003-06424 TUYEN Q LE TO: TUYEN Q LE 1023 DREXEL HILLS BLVD NEW CUMBERLND, PA 17070-1737 COURT OF COMMON PLEAS COUNTY OF ~JMBERLAND N(.TICE Pursuant to Rule 236 of the Supreme Cmurt of Pennsylvania, you are hereby notified that a JUDGMENT BY DEFAULT has been entered against you in the above proceeding and that enclosed herewith is ~ copy of all the (record) documents filed in support of the said JUDGMENT. ~,ON(,ERNINt~ THIS NOTICE, PLEASE UALL: IF YOU HAVE ANY QUESTIONS I ERIC M. BERMAN, P.C., Attorneys at Law. Attention: Eric M. Berman, Esquire, or Robert M. Kline, at this telephone number. 1-610-265-772) - P~OTHO~OT~RY