HomeMy WebLinkAbout08-1087
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK T-
Plaintiff No: (?B - ?jy87 CiVC l ler*%
VS.
COMPLAINT IN CIVIL ACTION
GEORGE EUGEN SEIDLE 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 1400
Pittsburgh, PA 15219
(412) 434-7955
FAX: 412-338-7130
06362820 C A Pit SXA
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No Oj- 10J'7; P Tu-?
GEORGE EUGEN SEIDLE 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 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:
GEORGE EUGEN SEIDLE JR
813 WERTZVILLE RD
ENOLA, PA 17025
3. Defendant applied for and received a credit card issued by
Plaintiff bearing the account number XXXXXXXXXXXXXXXX8661 . 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 February 06, 2008 , in the amount of
$2231.38 .
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 , GEORGE EUGEN SEIDLE JR INDIVIDUALLY , in the
amount of $2231.38 with interest at the legal rate of 6.000 per annum
from date of judgment plus attorneys' fees of $500.00 , and costs.
James mbrodt,42524
WELT MAN, INBERG & REIS CO., L.P.A.
436 Sev n h Avenue, Suite 1400
Pittsb rg , PA 15219
(412) 43 -7955
FAX: 412 338-7130
063 282 C A Pit SXA
This law firm is a debt collector att&tjng to collect this debt for
our client and any information obtair?e d ill be used for that purpose.
C 4?
$2,231.38 I $2,231.38 I Enter Amount Enclosed Below
15 SDSN6A01 0005572
GEORGE SEIDLE JR
813 WERTZVILLE RD
ENOLA PA 17025-1834
Payment Due Date $
November 14, 2007 Please make check payable to Discover Card.
Minimum pa ment due includes a past due
amount of $489.00.
Make payments on your schedule, in
advance or on the same day as your due
date. Visit Dlsooveroard.oomlpayments
j ' to make an online payment today.
PO BOX 15251 111ur1loll ru111111u11.11
pa WILMINGTON DE 19886-5251
above, or go to Discovelrcard. om Printlyour e-mail addre s to
?tr???nn???i?nt
receive important Account information and special offers.
0000060110021806286610223138000000002 138
Discover Card Account Summary
Account number ending in
Payment Due Date
Minimum Payment Due
Credit Limit
Credit Available
Cash Credit Limit
Cash Credit Available
Closing Date: October 15, 2007 page 1 of 1
8661 Previous Balance $2
231.38
November 14, 2007 Payments And Credits ,
000
$2,231.38 Purchases + 0
00
$2.000•00 Cash Advances .
$0.00
Balance Transfers + 0.00
+ 0
00
$0.00 Finance Charges .
+ 0
00
$0.00 New Balance .
= $2,231.38
%.asnback bonus's
Cashback BonusO Anniversary
Date: June 15
Opening Cashback Bonus Balance
New Cashback Bonus Earned
Cashback Bonus Balance
Available to Redeem
$ 0.00
+ 0.00
$ 0.00
$ 0.00
Mow Gan 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 STOO alt Lake City, (Telecommunications 84130
Customer Servke: 1-800-DISCOVER (1-800-347.2683) For msee ese side. for the Deaf):
Transactions $0 Fraud Liability Guarantee Use your Discover Card with cnnfirlnnrn
intormation 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?F outstanding balance of
purchases and balance transfers. However, we reserve the right to increase th IX I nt if you fail to pay the
minimum payment due by the payment due date. See the Default Rate Plan section of the C member Agreement for
details.
Finance Charge Summary
Average Daily
Daily Periodic Nominal
ANNUAL
PERCENTAGE
ANNUAL
PERCENTAGE
Periodic Transaction
Fee
Balances Rates
RATES
RATES FINANCE
C GES FINANCE
CHARGES
current billing period: 15 days
Purchases
Cash Advances $0 0.07463%
$0 0
07463%
27.24% V
27.24%
$0
none
.
previous billing period: 12 days 27.24/o V 27.24% $0 $0
Purchases $0 0.07600% 27.74% V 27.74%
$0
no
The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above. ne
Wish you could sort these purchases by amount, description or category? You can - register at Discovercard.com to view
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
(Name)
ACCOUNT 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 are true and correct to the best of his/her knowledge, information and belief.
(Signature)
WWR# 06362820
DFS# 6011002180628661
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SHERIFF'S RETURN - REGULAR
CASE NO: 2008-01087 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DISCOVER BANK
VS
SEIDLE GEORGE EUGEN JR
GERALD WORTHINGTON , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
SEIDLE GEORGE EUGEN JR
the
DEFENDANT , at 1515:00 HOURS, on the 21st day of February , 2008
at 813 WERTZVILLE RD
ENOLA, PA 17025
by handing to
ALISON MACAM, FIANCE ADULT IN CHARGE
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 13.44
Affidavit .00
Surcharge 10.00
00
-4/D 3/o P 41.44
Sworn and Subscibed to
before me this day
So Answers:
R. Thomas Kline
02/22/2008
WELTMAN WEINBERG REIS
By:
Deputy Sh ff
of A. D.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS.
GEORGE EUGENE SEIDLE JR
Defendant
No. 08-1087 CIVIL TERM
PRAECIPE FOR DEFAULT JUDGMENT
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan, Esquire
PA I.D.#47437
Weltman, Weinberg & Reis Co., L.P.A.
1400 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#6362820
Judgment Amount $ 2,531.38
THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY
INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE.
IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS.
GEORGE EUGENE SEIDLE JR
Defendant
TO THE PROTHONOTARY:
Civil Action No. 08-1087 CIVIL TERM
PRAECIPE FOR DEFAULT JUDGMENT
Kindly enter Judgment against the Defendant, RICHARD L BURGAR.D above named, in the default of an
Answer, in the amount of $2,531.38 computed as follows:
Amount claimed in Complaint $2,231.38
Interest from date of judgment
at the legal interest rate of 6.00% per annum
Attorney's fees $300.00
TOTAL $2,531.38
I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA
R.C.P. 237.1 on the dates indicated on the Notices.
WELTMAN, WEINBERG & REIS CO., L.P.A.
r?
By:
William T. Molcza , Esquire
PA I.D.#47437
Weltman, Weinberg & Reis Co., L.P.A.
1400 Koppers Bldg.
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
WWR#6362820
Plaintiff's address is:
c/o Weltman, Weinberg & Reis Co., L.P.A.,1400 Koppers Building, 436 7 h Avenue, Pittsburgh, PA 15219
And that the last known address of the Defendant is: 813 WERTZVILLE RD, ENOLA,PA 17025
THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
GEORGE EUGENE SEIDLE JR
Defendant
TO:GEROGE EUGENE SEIDLE JR
813 WERTZVILLE RD
ENOLA, PA 17025
IMPORTANT NOTICE
Date of Notice: oilhm o6
WWR#:6362820
CASE# Qg `lQU-4` CIVIL (Er O)
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN
APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR
DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT
WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED
AGAINST YOU WITHOUT A HEARING AND YOUOMAY LOSE YOUR PROPERTY OR OTHER
IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO A LAWYER AT ONCE. IF YOU
DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH
BELOW. 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 REFERRAL SERVICE
CUMBERLAND COUNTY BAR ASSOCIATION
32 SOUTH BEDFORD STREET
CARLISLE, PA 17013
(717) 249-3166
Y :T- U )OaavL ?
BY:-
PATRICK THOMAS WOODMAN
PA I.D. #34507
WELTMAN WEINBERG & REIS CO., L.P.A
1400 KOPPERS BLDG, 436 7TH AVE.
PITTSBURGH, PA 15219
(412) 434-7955
IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs
GEORGE EUGENE SEIDLE JR
Case no: 08-1087 CIVIL TERM
NON-MILITARY AFFIDAVIT
Defendant
The undersigned, who first being duly sworn, according to law, deposes and states as follows:
That he/she is the duly authorized agent of the Plaintiff in the within matter.
Affiant further states that the within Affidavit is made pursuant to and in accordance with the
Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. § 521.
Affiant further states that based upon investigation it is the affiant's belief that the Defendant, RICHARD L
BURGARD is not in the military service.
Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data
Center (DMDC), which states that the Defendant, RICHARD L BURGARD is not in the military service.
Further Affiant sayeth naught.
t;- -
AFFIANT
SWORN TTO1 AND SUBSCRIBED in my presence this day
of V r I COMMONWEAL) H OF PE-NNSYLVANIA
[??;tariai Se?3
Wayne A..ir;r?? s, Notary Public
N ARY PUB.LI City Of Pittsburgh, Ak,,jheny County
My Commission t? June 29, 2010
PJiember, Penrsl?: ,i rtssovivtion or Notarie3
This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be
used for that purpose.
Request for Military Status
Department of Defense Manpower Data Center
Military Status Report
Pursuant to the Servicemembers Civil Relief Act
Page 1 of 1
MAY-13-2008 11:19:28
' Last Name First/Middle Begin Date Active Duty Status Service/Agency
SEIDEL JR GEORGE EUGENE Based on the information you have furnished, the DMDC does
not possess any information indicating that the individual is
currently on active duty.
Upon searching the information data banks of the Department of Defense Manpower Data Center, based
on the information that you provided, the above is the current status of the individual as to all branches
of the Military.
fn 101,4,
Mary M. Snavely-Dixon, Director
Department of Defense - Manpower Data Center
1600 Wilson Blvd., Suite 400
Arlington, VA 22209-2593
The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that
maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the
official source of data on eligibility for military medical care and other eligibility systems.
The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act
[50 USCS Appx. §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940).
DMDC has issued hundreds of thousands of "does not possess any information indicating that the
individual is currently on active duty" responses, and has experienced a small error rate. In the event the
individual referenced above, or any family member, friend, or representative asserts in any manner that
the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly
encouraged to obtain further verification of the person's active duty status by contacting that person's
Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on
active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA
may be invoked against you.
If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle
name), you can submit your request again at this Web site and we will provide a new certificate for that
query.
This response reflects current active duty status only. For historical information, please contact the
Military Service SCRA points-of-contact.
See: http://www.defenselink.mil/face/pis/PC09SLDR.html
WARNING: This certificate was provided based on a name and Social Security number (SSN) provided
by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided.
Report ID: SJSYEKJQDS
https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 5/13/2008
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IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs. Civil Action No. 08-1087 CIVIL TERM
GEORGE EUGENE SEIDLE JR
Defendant
NOTICE OF JUDGMENT OR ORDER
TO: ( ) Plaintiff
(xx) Defendant
( ) Garnishee
You are hereby notified that the following
Order or Jud ent was entered against you
on .5 flug/d
(xx) Assumpsit Judgment in the amount
of $2,531.38 plus costs.
( ) Trespass Judgment in the amount
of $ plus costs.
( ) If not satisfied within sixty (60)
days, your motor vehicle operator's license and/or registration
will be suspended by the Department of Transportation, Bureau
of Traffic Safety, Harrisburg, PA.
(xx) Entry of Judgment of
( ) Court Order
( ) Non-Pros
( ) Confession
(xx) Default
( ) Verdict
( ) Arbitration
Award
Prothonotary
By:
PRO ONOTA D UTY)
GEORGE EUGENE SEIDLE JR
813 WERTZVILLE RD
ENOLA,PA 17025
Plaintiffs address is:
c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7'h Avenue, Pittsburgh, PA 15219
1-888-434-0085