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Home My WebLink About08-03514 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: M- 35( CtV< (7,-r" VS. ROBERT C BECK 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 06307919 C A Pit WLG IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No ROBERT C BECK 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 I 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: ROBERT C BECK 1248 MOUNT PLEASANT RD PENFIELD, PA 15849 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011002665513388 . 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 18, 2007 , in the amount of $6155.59 . 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 $1000.00 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 , ROBERT C BECK INDIVIDUALLY , in the amount of $6155.59 with interest at the legal rate of 6.00001 per annum from date of judgment plus attorneys' fees of $1000.00 , and costs. ./ - James Warmbrodt,42524 WELT WEINBERG & REIS CO., L.P.A. 436 S e th Avenue, Suite 2718 Pitt u h, PA 15219 (41 4 4-7955 F 4 2-338-7130 0 07 19 C A Pit WLG This law firm is a debt collector aeWting to collect this debt for our client and any information obta n d will be used for that purpose. vIJ\.1111 V CK 46,155.59 J $6,155.59 ' I '- "-, "" all woo CARD Enter Amount Enclosed Below Payment Due Date October 21, 2007 Please make check payable to Discover Card. Minimum pa ent due includes a past due 22 SDSN6A01 0007625 amount of $11,1m19.00. ROBERT BECK ? t Manage your budget, track your spending 1248 MOUNT PLEASANT RD lJ ?! and avoid fees with FREE time) e-mail PENFIELD PA 15849-6530 reminders. To find out more, visit Discovercard.com/reminders L)}/_ f. PO BOX 15251 Address, e-mail or telephone change? Print change in space WILMINGTON DE 19886-5251 above, or go to Discovercard.com. Print your e-mail address to receive important Account information and special offers. 000006011002665513388061555900000000615559 Discover More Card Account Summary Closing Date: Account number ending in 3388 Payment Due Date October 21 Minimum Payment Due , $6,155.59 Credit Limit $4,800.00 Credit Available $0.00 Cash Credit Limit $0.00 Cash Credit Available $0.00 September 22, 2007 page 1 of 1 Previous Balance 2007 Payments And Credits $6,155.59 Purchases 0'? Cash Advances + 0.00 Balance Transfers + 0.00 Finance Charges + 0.00 New Balance ----+__ 0_-00 $6,155.59 Cashback Bonus® Opening Cashback Bonus Balance $ 0,00 Now Cashback Bonus Earned = 00 Cashback Bonus Cashback Bonus® Anniversary Ay Iable to Redeem lance $ 0.00 Date: February 22 $ 0.00 How Can We Help You? For Account Inquiries, write to us at. Please have your Discover Card available. Discover More Card, PO Box 309,43 Manage your account online at Discovercard.com Salt Lake City, UT 8,4130 Customer Service: 1.800 DISCOVER (1-800-347-2683 TDD (Telecommunications Device for the Deaf); For assistance, see reverse side. -------------- Transactions $0 Fraud Liability Guarantee Use your Discover Card with confid ence. 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 Defa wit R to Ian s details. c ,o a Cardmember Agreement for Finance Charge Summary Averse g e Daily Periodic Nominal ANNUAL PERCENTAGE ANNUAL Periodic Transaction Fee B ala c s Rates RATES PERCENTAGE RATES RG S FC f G current billing period: 22 days E C A ES Purchases $0 Cash Advances $0 0.07942% 28.99% F 28.99% $0 previous billing period: b days 0.07942% 28.99% F 28.99% $0 none $0 Purchases $0 0.07942% 28.99% F 28.99% The rates that apply to your Account are either fixed (F) or the y may vary (V) as noted above. VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsifications to authorities, that he/she is Robert Adkins (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. G? (Signature) WWR # 6307919 ROBERT C BECK 6011002665513388 W O R- r t C7 G 00 w:, (? ?'` w ITT ! ! } 77 0 r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. ROBERT C BECK Defendant No. 08-351-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, Esquire PA I. D. #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6307919 01 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 08-351-CIVIL TERM ROBERT C BECK 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: James C. Wa PA I. D. #425'e 1400 Koppe 436 Seven rodt, Esquire Building Pittsburg 7-'79 PA 1 19 (412) 557 Notarial Seat _ EW401yhe . Jones Notary Public 7urgh, f111,1,gheny County on 29, 2010 Member, Pennsyly on of No2r.es SWORN TO AND SUBSCRIBED before me this 0? r?? day rv ca t` cx. * V 1