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Home My WebLink About08-0356 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: VS. COMPLAINT IN CIVIL ACTION DAVID BESSELMAN JR 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 06362978 C A Pit WLG I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No DAVID BESSELMAN JR 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 seE 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: DAVID BESSELMAN JR 402 LAKE DR MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXXXXXX7785 . 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 31, 2007 , in the amount of $8678.52 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 I 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 , DAVID BESSELMAN JR INDIVIDUALLY , in the amount of $8678.52 with interest at the legal rate of 6.000W per annum from date of judgment plus attorneys' fees of $1000.00 , and costs. James armbrodt,42524 WELT INBERG & REIS CO., L.P.A. 436 S ven Avenue, Suite 2718 Pitt urg , PA 15219 (41 43 -7955 FAX. 41 -338-7130 06 629 C A Pit WLG This law firm is a debt collector att mp ing to collect this debt for our client and any information obtain will be used for that purpose. I 1%0%0 A' • CR $8,67'8.32 I $919.00 CARD Payment Due Date November 24, 2007 25 SDSN6A01 0005736 - DAVID BESSELMAN JR 2497 COPE DR MECHANICSBURG PA 17055-5355 1 Account (Number ending in 77135 Enter Amount Enclosed Below Please make check payable to Discover Card. Minimum payment due includes a post due amount of $726.00. Make payments on your schedule, in advance or on the same day as your due date. Visit Disooveroerd.oom/payments to make an online payment today. PO BOX 15251 11 Address, e-mail or telephone change? Print change ins ace WILMINGTON DE 19886-5251 above, or go to Discovercord.com. Print your e-mail address to receive important Account information and special offers. 000006011002630047785086785200000000091900 Discover Card Account Summary Account number ending in 7785 Closing Date: October 25, 2007 page 1 of 1 Payment Due Date November 24, 2007 Minimum Payment Due $919 00 Previous Balance Payments And Credits $8,464.38 . Credit Limit 800 00 $9 Purchases 0.00 . . Credit Available $0 00 Cash Advances + 35.00 . Cash Credit limit $4 900 0o Balance Transfers + 0.00 , . Cash Credit Available $0 00 Finance Char + 0.00 . New Balance + 17914 . 52 You may be able to avoid Periodic Finance Cha b reverse side for details. rges, see the Cashback Bonus® O pening Cashback Bonus Balance New Cashbock Bonus Earned 00 $ 0 . Cashback Bonus® Anniversary D Cashback Bonus Balance Available to Red 00 $ 0 ate: June 25 - eem . $ 0.00 How Can We Help You? For A 'Please have your Discover Card available ccount Inquiries, write to us at. Discover More Card PO B . Manage your account online of Discovercard.com , ox 30943 Soh Lake City, UT 8,4130 Customer Service: 1-8MDISCOVER (I.800.347.2683 ) TDD (Telecommunications Device for the De a?: For assistance see r Transactions , everse side. $0 Fraud Liability Guarant U Trans. Post ee se your Discover Card with confidence. Date Date Other/Miscellaneous Oct 25 Oct 25 LATE FEE Information For You 35.00 Finance Charge Summary Avers Nominal Dail ga Daily ANNUAL ANNUAL Transaction Y Periodic PERCENTAGE PERCENTAGE PFIN eriodic Fee Balance Rates RATES RATES CMRGES CHARGES current billing period: 30 days Purchases $8550.64 0.06984% 'Cash Advances $0 25.49% V 25.49% $179.14 0.05477% 19.99% F 19.99% none The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above. $0 $0 Wish you could sort these purchases by amount, description or category? You can - register at Discovercard.com to view your purchases online as for back as 12 months. Learn mnm m f * * * ATTENTION * * * Your account is seriously past due. Payments should be made immediately. Payment of the amount due and arrangements for future 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. 'Al III, x2 (Signature) WWR # 6362978 DAVID BESSELMAN 6011002630047785 * z.> UI y r'tJ '" 1 C SHERIFF'S RETURN - REGULAR CASE NO: 2008-00356 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS BESSELMAN DAVID JR WILLIAM CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BESSELMAN DAVID JR the DEFENDANT , at 1904:00 HOURS, on the 18th day of January , 2008 at 402 LAKE DRIVE MECHANICSBURG, PA 17055 TRACY BESSELMAN, WIFE 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 Service Affidavit va V b 18.00 Surcharge 10.56 .00 10.00 00 8 56 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 01/22/2008 WELTMAN WEINBERG REIS By. < eput S eriff of A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. DAVID BESSELMAN JR Defendant No. 08-356 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END WITH PREJUDICE 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#06362978 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 08-356 CIVIL TERM DAVID BESSELMAN JR Defendant PRAECII'E TO SETTLE DISCONTINUE AND END WITH PREDJUDICE TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue the above captioned matter upon the records of the Court with prejudice and mark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: JAMES C R PA I.D #4 52 WELT N, INB 2718 K pper Buildin 436 S ent Avenue Pitts r A 15219 (41 ) 4 -7955 W #06362978 Sworn to and subscribed Before me the a 9 Aay of FEBRUARY, 2008 PUB & REIS CO., L.P.A. Fa 1 f? ???i., Cf 0 -A