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Home My WebLink About08-0220A 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: D$' aao 0-Ava-r-. vs. JUDITH M HUGGLER COMPLAINT IN CIVIL ACTION Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 062.58635 C A Pit CXC IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No JUDITH M HUGGLER Defendant COMPLAINT AND 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 an 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 the complaint or for any other claim or relief requested 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. 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 REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 4 COMPLAINT 1. Plaintiff, is a corporation with offices at 6500 New Albany Rd, New Albany, OH 43054. 2. Defendant is adult individual(s) residing at the address listed below: JUDITH M HUGGLER 300 CENTER ST ENOLA, PA 17025 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011002600301899 . A copy of Plaintiff's Statement of Account s attached hereto, marked as Exhibit "A" and made a part hereof. 4. Defendant made use of said credit card and currently has a balance due and owing to Plaintiff, as of December 14, 2007 , in the amount of $2502.24 . 5. Defendant is in default by failing to make payments when due. 6. Plaintiff avers that the Agreement between the parties provides that Defendant will pay Plaintiff's attorneys' fees. 7. Plaintiff avers that such attorneys' fees will amount to $500.00 8. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due to Plaintiff. Wherefore, the Plaintiff prays for Judgment in its favor and against Defendant , JUDITH M HUGGLER INDIVIDUALLY , in the amount of $2502.24 with interest at the legal rate of 6.00016 per annum from date of judgment plus attorneys' fees of $500.00 , and costs. James C. 4rmbro3t?42524 WELTMAN INBERG & REIS CO., L.P.A. 436 Se ent Avenue, Suite 2718 Pitts urg , PA 15219 (412 434 7955 FAX: 412 338-7130 062 863 C A Pit CXC This law firm is a debt collector attejnp?&ng to collect this debt for our client and any information obtain will be used for that purpose. ®75Q, VEK CARD --- .........._..._ $2,502.24 I $2,502.24. I Enter Amount Enclosed Below Payment Due Date September 21, 2007 22 SDSN6A01 0008086 lL T t JUDITH HUGGLER 300 CENTER ST ?r ENOLA PA 17025-2607 EXHIBIT Address, e-mail or telephone change? Print change in space above, or go to Discovercard.com. Print your e-mail address to receive important Account information and special offers. Please make check payable to Discover Card. MinimuAMP* nt due includes a past due amount .00. Manage your budget, track your spending and avoid fees with FREE timely e-mail reminders. To find out more, visit Discovercard.com/reminders PO BOX 15251 111111111111111111 lill sill 1111 WILMINGTON DE 19886-5251 000006011002600301899025022400000000250224 Discover More Card Account Summary Closing Date: August 22, 2007 page 1 of 1 Account number ending in Payment Due Date 1899 September 21 2007 Previous Balance P $2,502.24 Minimum Payment Due , $2,502.24 ayments And Credits Purchases 0.00 Credit Limit $2,000.00 Cash Advances + 0.00 Credit Available $0.00 Balance Transfers + 0.00 Cash Credit Limit $0.00 Finance Charges + 0.00 Cash Credit Available $0.00 New Balance + 000 a $2,502.24 Cashback Bonus® Opening Cashback Bonus Balance $ 0.00 New Cashback Bonus Earned + 000 Cashback Bonus Balance $ 0.00 Cashback Bonus® Anniversary - - - - - - - - - - - - - - - - - - - - - - - Available .to- Redeem - - -. _ _ _ - $- - - - - - - -0-OO- Nis: October 22 How Can We Help You? For Account Inquiries, write to us at: Please have your Discover Card aveJabls. Discover More Card, PO Box 30943 Manage your amount online of Discowreard.com Salt Lake City, UT 84130 Custornor Service: 1-800-DISCOVER (1-800-347-2683 Fop (Telecommunications Device for the peat): For assistance, see reverse side. Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence. Information For You While we are permitted under the Cardmember Agreement to increase the APRs on your Account because your payment was late, we have chosen not to do so at this time. We have terminated, however, any introductory or promotional rate on purchases and any special balance transfer rate, and applied the standard APR for purchases to your outstanding balance of purchases and balance transfers. However, we reserve the right to increase the APRs on your Account if you fail to pay the minimum payment due by the payment due date. See the Default Rate Plan section of the Cardmember Agreement for details. Finance Charge Summary Average Daily Daily dic Nominal ANNUAL PERCENTAGE ANNUAL P E NTAGE Periodic Transaction Fee Balances Rates R TES FINANCE CAS FINANCE current billing period: 31 days CHARGES Purchases $0 Cash Advances $0 0.07737% 28.24% V 28.24% $0 none previous billing period: 22 days 0.07737% 28.24% V 28.24% $0 $0 Purchases $0 0.077379', 28.24% V 28.24% $0 The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above. none VERIFICATION The undersigned does hereby verify subject to thepenalties off 18PA.C.S. §4904 relating to unworn falsifications to authorities, that he/she isAh?, -. A"i?_4 (Name) Accounts Manager of DFS Services, LLC , plaintiff herein, that (Title) (Company) he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of his/her knowledge, information and belief. (Signature) WWR # 6258635 JUDITH M HUGGLER 6011002600301899 r + ' n SHERIFF'S RETURN - REGULAR CASE NO: 2008-00220 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS HUGGLER JUDITH M SHARON LANTZ Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE HUGGLER JUDITH M was served upon DEFENDANT the at 1727:00 HOURS, on the 15th day of January , 2008 at 300 CENTER STREET ENOLA, PA 17025 JUDITH HUGGLER by handing to 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 15.36 Affidavit .00 Surcharge 10.00 00 //,2 ` M 43*36 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 01/16/2008 WELTMAN WEINBERG RREIS V,/- By : n z , ?? ? / Deputy Sher A.D. ?? ? 5 CO U? 13?N1? Ju -D I -ry m - dA6 (" L- L?-,-k C?42# b?-aa.o eiVij7er, fj u aA,-ic7 r?, Co L4 4it UO-q My '-?#-?- Vlt,? Y,4",?Ot altoL N Cy-, 14 L? eliz y r rall a? AWi-nd- Wa-o rp pal?? dA ,00 00 1 3A flo-A 4 ? n w " I (?, al'Y?L 6- 41 PJ lie ivel ?? a u?a a ,?,,o h `? 4 V, bv? 4- W CA vo w IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. JUDITH M HUGGLER Defendant No. 08-220 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C. WARMBRODT PA I. D #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06258635 w IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 08-220 CIVIL TERM JUDITH M HUGGLER Defendant PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR Settle, Discontinue and End the above-captioned matter upon the records of the Court without prejudice to refile and mark the costs paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: Attorney f r intiff 2718 Ko pers uilding 436 Se enth enue Pittsb rgh, P 15219 (412 434-79 5 SWORN TO AND SUBSCRIBED before me this 10 day of fon , 2008 OTAR IC COMMONWEALTH OF PENNSYLVANIA =Wendy araal Seal ault, Notary Public h, Allegheny County Fyoir? :.isiy 15,201 0 Member, PennsVK=,4 i:n or Notaries C) ; C- S 66 ?syy -Tj -'r " 1 * ? film Z cri he