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Home My WebLink About08-1358 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. TIMOTHY S KLINE Defendant No : 66 - 1368 ?lUl COMPLAINT IN CIVIL ACTION 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 06413890 C A Pit SXA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No TIMOTHY S KLINE 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: TIMOTHY S KLINE 210 ROSS AVE NEW CUMBERLAND, PA 17070 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXXXXXX6091 . 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 08, 2008 , in the amount of $6521.87 . 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 Iar-fendant , TIMOTHY S KLINE INDIVIDUALLY , in the amount of $6521.87 with interest at the legal rate of 6.000% per annum from date of judgment plus attorneys' fees of $1000.00 , and costs. James C armbrodt,42524 WELTMAV INBERG & REIS CO., L.P.A. 436 S en Avenue, Suite 1400 Pitts urg , PA 15219 (412) 43 -7955 FAX: 41 338-7130 064 389 C A Pit SXA This law firm is a debt collector attej Ming to collect this debt for our client and any information obtaine ill be used for that purpose. DISER c RD New Balance $6,521.87 22 SDSN6A01 0006844 TIMOTHY KLINE 210 ROSS AVE NEW CUMBERLND PA 17070-2614 Minimum Payment Due I $6,521.87 Account Number ending in 6091 Enter Amount Enclosed Below Payment Due Date December 21, 2007 Please make check payable to Discover Card. Minimum payment due includes a past due amount of $1,219.00. Make payments on your schedule, in advance or on the same day as your due date. Vielt Disooveroard.oom/payments to make an online payment today. PO BOX 15251 1111r1111111rh1111111111r1 WILMINGTON DE 19886-5251 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. 000006011002860556091065218700000000652187/ f Discover More Card Account Summary Closing Date: November 22, 2007 page 1 of 1 Account number ending in Payment Due Date Minimum Payment Due Credit Limit Credit Available Cash Credit Limit Cash Credit Available 6091 December 21, 2007 $6,521.87 $5,300.00 $0.00 $0.00 $0.00 Previous Balance $6,521.87 Payments And Credits 0.00 Purchases + 0.00 Cash Advances + 0.00 Balance Transfers + 0.00 Finance Charges + 0.00 New Balance $6,521.87 Cashback Bonus® Opening Cashback Bonus Balance $ 0.00 New Cashback Bonus Earned + 0.00 Cashback Bonus Balance $ 0.00 Cashback Bonus® Anniversary Available to. Redeem . _ .. .. $ .. _ .. _0.00. Date: February 22 How Can We Help You? For Account Inquiries, write to us at. Discover More Card, PO Box 30943 Please have your Discover Card avodable. Salt Lake City, UT 84130 Manage your account online at Discovercard.com MD (Telecommunications Device for the Dea fl: Customer Service: 1-800-DISCOVER (1-800-347-2683) 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 Cordmember Agreerent 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. f u; Finance Charge Summary Nominal Transaction Average Daily ANNUAL ANNUAL Periodic Fee Daily Periodic PERCENTAGE PERCENTAGE FINANCE FINANCE Balances Rates RATES RATES CHARGES CHARGES current billing period: 22 days Purchases $0 0.07942% 28.99% F 28.99% $0 none Cash Advances $0 0.07942% 28.99% F 28.99% $0 $0 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 # 6413890 TIMOTHY S KLINE 6011002860556091 a 11.E c? `i9 ?J IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. TIMOTHY S KLINE Defendant No. 08-1358 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: MATTHEW D. URBAN, ESQUIRE PA I.D #90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06413890 I IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 08-1358 CIVIL TERM TIMOTHY S KLINE 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 for Plaintiff 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#06413890 SWORN TO AND SUBSCRIBED before me this :3 day of ?r J, 2008 ARY PU ct naa40r? ?1!?,t.±r1 OF fvr=a `YL.uaN1 9 .f S4'y Pti .Sr,rs°ra , f`er?favy 'kif c fr i.. rttdf:t?F? It ; kif""i?r; y County YP' t s 29, 2010 t ;of„ber, Pennsyfvanij Association of Notaries I #' L O IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. TIMOTHY S KLINE Defendant(s) 08-1358 No. PRAECIPE FOR SATISFACTION OF JUDGMENT 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) 434-7999 WWR#6413890 DIS 16 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 2008-SU-005259-01 TIMOTHY S KLINE 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. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. Wa m rodt, Esquirc? PAID.#4 2 WELTMA EINBERG & REIS CO., L.P.A. 1400 Kop ers uilding 436 Sev th venue Pittsbur h, A 15219 (412) 4 4 999 WWR #6413890 Sworn to and subscribed before me this 10 day of September, 09 O Y PU C f COMMONWEALTH GF PENNSVLVANIA Notarial Seal Wayne K Jones, Notary Public CK of PlttebO. AIlNpIWWW County 20,2010 member. Mir Comn Penns d Neowe _ n o Notaote rbs OF T HE P? A7 2009 SEP 18 Fi i L'. "14 CU -k t rra ;i'i'3 rL:NN Y 0