HomeMy WebLinkAbout08-0359IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff No: 359 Civi I Terw%
vs.
COMPLAINT IN CIVIL ACTION
LISA M SETTA
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
06362972 C A Pit WLG
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No
LISA M SETTA
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
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:
LISA M SETTA
143 PENNSYLVANIA AVE
CARLISLE, PA 17013
3. Defendant applied for and received a credit card issued by
Plaintiff bearing the account number XXXXXXXXXXXXXXXX9227 . 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
$4952.51
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 , LISA M SETTA INDIVIDUALLY , in the amount of
$4952.51 with interest at the legal rate of 6.000% per annum from date
of judgment plus attorneys, fees of $500.00 , and costs.
James-C/ W rmbrodt,42524'
WELT y :BERG & REIS CO., L.P.A.
436 S Avenue, Suite 2718
Pitts PA 15219
(412 955
FAX: 48-7130
063 29 A Pit WLG
This law firm is a debt collector att ing to collect this debt for
our client and any information obtain will be used for that purpose.
Low% V CR $4,952.51
CARD
08 SDSN6A01 0005730
LISA SETTA
143 PENNSYLVANIA AVE
CARLISLE PA 17013-1141
- - ^"uunr Numcer ending in Y227
$4,952_51 _ J Enter Amount Enclosed Below
Payment Due Date ?
DUE IMMEDIATELY
Make payments on your schedule, in
advance or on the same day as your due
date. Visit Disooveroard.oom/payments
to make an online payment today.
PO BOX 15251 111...
Address, e-mail or telephone change? Print change ins Ce WILMINGTON DE 19886-5251
above, or go to Discovercard.com. Print your e-mail add ess to I111111,1,i,1,1,1,1,,,,
receive important Account information and special offers.
000006011002615479227049525100000000495251
Discover Card Account Summary
Closing Date: October 8
2007
,Account number ending in 9227 , page 1 of 1
Payment Due Date
Minimum Pa
ment D November 7, 2007 Previous Balance
Payments And Credits $4,952.51
y
ue
Credit Limit $4,952.51
$4
000
00 Purchases 0'00
00
+ 0
Credit Available ,
.
$0.00 Cosh Advances
Balance Transf .
+ 0.00
Cash Credit Limit
Cash Credit Available $0.00
$0
00 ers
Finance Charges + 0.00
+
. -___
New Balance 0,00
_ $4,952.51
Cashback Bonus® Opening Cashback Bonus Balance
New Cashback Bonus Earned $ 0.00
+ 0 00
Cashback Bonus® Anniversary Cashback Bonus Balance
$ 0.00
Available to Redeem $ 0.00
Date: October 8
'How Can We Help You? For Account.lnquiries, write to us at.
Please have your Discover Card ovatlable. Discover More Card, PO Box 30943
Sao Lake your account online of Discovereard.com City, UT 84130
Customer Service: 1.800-DISCOVER (1-800-347-2683) TD For D asssistasistaonccee, , see rever see revers Device for the Deaf):
se 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.
cAH1811
Finance Ch
S
arge
ummary
Averse
Dail g Daly
Y Periodic
Balances Nominal
ANNUAL ANNUAL
PERCENTAGE PERCENTAGE
FIN
FIN
Transaction
Fee
Rates
current billing period: 8 days RATES RATES ANC
ANCE
CHARGES FINANCE
R S
Purchases $0 0.06573%
Cash Advances $0 23.99% F 23.99%,
$0
0.07121%
previous billing period: 21 days
25.99% F 25.99%
$0 none
$0
Purchases $0 0.06573% 23.99% F
23.99%
$0
The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above. none
Wish you could sort these purchases by amount, description or category? You can - re ister at Discovercard.com to view
your purchases online as for back as 12 months. Learn mnrn ,,, n,<...,..e. -A ___ ?-...
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.
(Signature)
WWR # 6362972
LISA M SETTA
6011002615479227
-
pO cry . !
R? W
O - ,-
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A
i 1
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-00359 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DISCOVER BANK
VS
SETTA LISA M
TIMOTHY BLACK , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
SETTA LISA M the
DEFENDANT , at 1410:00 HOURS, on the 18th day of January , 2008
at 143 PENNSYLVANIA AVENUE
CARLISLE, PA 17013
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 4.80
Affidavit .00
Surcharge 10.00
00
32.80
Sworn and Subscibed to
before me this day
of ,
So Answers:
R. Thomas Kline
01/22/2008
WELTMAN WEINBERG REIS
By:
Deputy Sheriff
A. D.
4
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS.
LISA M SETTA
Defendant
No.08-359 CIVIL TERM
PRAECIPE FOR ENTRY OF
JUDGMENT BY CONSENT
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
Benjamin R Bibler, Esquire
PA I.D. #93598
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#6362972
$6531.01
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS.
LISA M SETTA
Defendant
Civil Action No. 08-359 CIVIL TERM
PRAECIPE FOR JUDGMENT BY CONSENT
TO THE PROTHONOTARY:
Kindly enter Judgment against Defendant, LISA M SETTA, in the amount of $6531.01 plus costs, based upon
the consent of the parties.
CONSENTED TO:
WELTMAN, WEINBERG & REIS CO., L.P.A.,
By:
Atto ey r aintif
LISA M SETTA,
By: ( d
Defendant
WWR#6362972
. -Wk
U b 1 4 ,_
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
LISA M SETTA
Defendant(s)
No. 08-359 CIVIL TERM
PRAECIPE FOR SATISFACTION OF
JUDGMENT
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
Lyndsay E Rowland, Esquire
PA I.D. # 205520
WELTMAN, WEINBERG & REIS CO., L.P.A.
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR46362972 DIS
A
elm y??? s5
I
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No. 08-359 CIVIL TERM
LISA M SETTA
Defendant(s)
PRAECIPE FOR SATISFACTION OF JUDGMENT
At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment.
WEL'
By:
Lyndsay E Ro land, E:
PA I.D. # 205 20
WELTMAN, EINBE
1400 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR #6362972
Sworn to and subscribed
before me this
day of Se tember„ l 0
OTARY PUBLIC COMMONWEALTH OF PENNSYLVANIA
Notarial Seal
L,4?G. Bevan, Notary Public
"wp,. Allegheny County
omr: a ssion L xplres Nov. 15, 2010
Member. Pennsvlvanla ASScOdation of Notaries
ERG & REIS CO., L.P A.
J.?L
ulre
& REIS CO., L.P.A.