The URL can be used to link to this page

Home My WebLink About03-6426Our File No_ 180729 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 DISCOVER BANK c/o ERIC M. BERMAN, P.C. 198 Allendale Road, Suite 306 King of Prussia, PA 19406 Vs. 83698 56479 COURT OF COMMON PLEAS ------x COUNTY OF CUMBERLAND TRIAL DIVISION CIVIL ACTION Term ROBERT L PHAM 210 LOCUST ST ENOLA, PA 17025 3167 -----------------------------------------X No.03 -lo?l??o ?rvc(?ER h 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. 180729 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. ROBERT L PRAM 210 LOCUST ST ENOLA, PA 17025 3167 -----------------------------------------X COMPLAINT 1. Plaintiff, DISCOVER BANK , CIVIL ACTION Term No. 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), ROBERT L PHAM , resides at 210 LOCUST ST , ENOLA, PA 17025-3167. 3. There is due from the Defendant(s) the sum of $6,732.36 for credit extended by Plaintiff to Defendant(s), acct. no. 6011002920292711, 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 $6,732.36 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 $6,732.36 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. BERMAN, P.C_ BY:\` ERIC M. BE`J, ESQUIRE BY. ROBERT M. KLINE ESQUIRE X COURT OF COMMON PLEAS COUNTY OF CUMBERLAND 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 true and correct. I understand to the penalties of 16 Pa C.S.A. falsifications to authorities. ERIC M_ BERMAN, Q(HRE C made in the within instrument are that false statements are subject Section 4904 relating to unsworn ROBERT M. KLINE, ESQUIRE Dated: OCTOBER 26, 2003 SPACEBNW-ZN (J „C 7J V r SHERIFF'S RETURN - REGULAR CASE NO: 2003-06426 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS PHAM ROBERT L VALERIE WEARY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PHAM ROBERT L the DEFENDANT , at 1009:00 HOURS, on the 15th day of December , 2003 at 210 LOCUST ST ENOLA, PA 17025-3167 by handing to NAOMI PHAM, WIFE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 10.35 Affidavit .00 Surcharge 10.00 .00 38.35 Sworn and Subscribed to before me this day of 1 kill- 3 A.D. ir"yj So Answers: R. Thomas Kline 12/16/2003 ERIC 13ERMAN By: ?.? Deputy Sheri DISCOVER BANK, : IN THE COURT OF COMMON PLEAS OF : CUMBERLAND COUNTY, PENNSYLVANIA Plaintiff : NO. 2003-6426 Civil Term VS. ROBERT L. PHAM, Defendant ENTRY OF APPEARANCE AS LOCAL COUNSEL Dear Sir: I hereby enter my appearance as local counsel, in conjunction with Robert M. Kline, Esquire, of the Law Office of Peter M. Berman, P.C., for the limited purpose of filing a Statement of Intention to Proceed. \ Date: October 24, 2006 Dale F. Shukhat , Jr . Supreme Cour r 19373 10 West High St et Carlisle, PA 17013 (717) 241-4311 cc: Robert M. Kline, Esquire, Law Office of Peter M. Berman, P.C. ? `s 3 ?r- xt Our File No. 180729 ERIC M. BERMAN, P.C. By: Robert M. Kline, Esquire Atty. ID.No. 56479 500 North Gulph Road, Suite 350 King of Prussia, PA 19406 (610) 265-7720 DISCOVER BANK vs. ROBERT L. PHAM Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION No. 2003-6426 STATEMENT OF INTENTION TO PROCEED TO THE PROTHONOTARY: Kindly mark the docket to reflect that Plaintiff, Discover Bank desires to proceed with this matter. BY: Dale F. Shughart, Jr., s i I.D. #19373 35 E. High Street Carlisle, PA 17013 (717) 241-4311 Local Counsel for Plaintiff Dated: October 24, 2006 jb'd 2S9LS92OT9 WUWM39 W 0163 WdL2=2 9002 ire 100 C') , tS 0 Curtis R. Long Prothonotary (Office of the Protbonotarp Cumberianb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor n2 -.1 q02?p CVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH DAY OF OCTOBER, 2009, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573