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Home My WebLink About08-1608IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIA CARD SERVICES, N.A. Plaintiff No: bg - Iton C1VzI Teri., VS. DAWNA M KULBACKI 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 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 06041062 C A Pit LXR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIA CARD SERVICES, N.A. Plaintiff VS. Civil Action No DAWNA M KULBACKI 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, FIA CARD SERVICES, N.A. is a corporation with offices at 2727 PACES FERRY RD,#1400 ATLANTA , GA 30339 . 2. Defendant is adult individual(s) residing at the address listed below: DAWNA M KULBACKI 418 N 21ST ST CAMP HILL, PA 17011 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXXXXXX9986 . 4. Defendant made use of said credit card and has a current balance due of $7924.62 , as of January 21, 2008 . 5. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff. 6. Plaintiff is entitled to the addition of interest at the rate of 7.000% per annum on the unpaid balance from January 21, 2008 . A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit 11111 and made a part hereof. 7. 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 , DAWNA M KULBACKI , INDIVIDUALLY , in the amount of $7924.62 with continuing interest thereon at the rate of 7.000% per annum from January 21, 2008 plus costs. James W rmbroCit,42524 WELT W INBERG & REIS CO., L.P.A. 436 S vent Avenue, Suite 1400 Pitt urg , PA 15219 (412 43 -7955 FAX- 41 -338-7130 060 1 2 C A Pit LXR 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. Bankof America 1 DAWNA Account Number: 4305 5003 3636 8348 Your Bank of America Visa® Account New Balance $6,930.83 Past Due Amount $1,315.23 Total Credit Line $0.00 Available Credit $0.00 Cash Limit $0.00 Available Cash $0.00 Overlimit Amount $930.83 Billing Date 10/14/06 Minimum Payment Due $1,601.71 Payment Due Date 11/08/06 24-Hour Customer Service 1.800.492.2500 Pay online! Visit For Lost or Stolen Cards 1.800.848.6090 www.bankofamerica.com Transactions View recent transactions and pay your bill online at www.bankofamerica.com POST. TRANS. REF. DESCRIPTION AMOUNT DATE DATE NO. CR=CREDIT Oct 09 Oct 09 LATE PAYMENT FEE $39.00 Oct 14 Oct 14 PERIODIC FINANCE CHARGE $180.36 Account Summary Previous Balance $6,711.47 Purchases + $0.00 Cash Advances + $0.00 Other Debits + $39.00 Credits $0.00 FINANCE CHARGE + $180.36 Payments $0.00 New Balance = $6,930.83 Past Due Amount = $1,315.23 Finance Charge Summary Corresponding Daily (D) / Monthly (M) Average Daily Minimum (M) / APR Periodic Rate Balance (ADB) Periodic (P) Charge Purchases 32.240% 0.08833%v D $6,805.95 $180.36 P Cash 32.240% 0.08833%v D $0.00 $0.00 P ANNUAL PERCENTAGE RATE 32.240% v=Variable Your account is over 90 days past due and closed to future use. This past due rating is being reported to the credit bureaus. To avoid further action, remit the "Min Payment Due" immediately. Call our Collections Department at 1.800.279.8962. BankofAmerica 'y Customer Corner Exi?isrt 0022600 0160171 0693083 4305500336368348 BANK OF AMERICA PO BOX 1516 NEWARK NJ 07101-1516 1111 It 1111111 1 111 11111111111111 11111 1111111111 1111111 11111 111 Payment Coupon Account Number 4305 5003 3636 8348 Payment Due Date 11/08/06 Total Minimum Payment Due $1,601.71 New Balance: $6,930.83 DAWNA M KULBACKI Amount Enclosed 418 N 21ST ST CAMP HILL, PA 17011-2201 $ 'ntiiiuti?'unulittt?i ttiti ttitiiltn ttl?itttii?tt'ni?n? Make check or money order payable to Bank of America. This is an electronic reproduction of your statement and includes account information only. 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 _ C (Name) of /?A„/c e4-, plaintiff herein, that (Title) T (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. WWR#06041062 J (Signature v n m PUB'OG ?p ?i,. C7 -n T' ") '? I s O p0 D ,' ??. OV SHERIFF'S RETURN - REGULAR CASE NO: 2008-01608 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIA CARD SERVICES NA VS KULBACKI DAWNA M 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 TJT TT MIAt'IT TIT TATTTTA M the DEFENDANT , at 1750:00 HOURS, on the 27th day of March , 2008 at 418 N 21ST STEET CAMP HILL, PA 17011 DAWNA KULBACKI 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: So Answers: Docketing 18.00 Service 14 .40f Affidavit .00 '`r{ l Surcharge 10.00 R. Thomas Kline .00 42.40L.--03/28/2008 WELTMAN WEINBERG REIS 3/aS1oA =/Yl Sworn and Subscibed to By: before me this day Deputy S iff of A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIA CARD SERVICES INC Plaintiff No. 08-1608-CIVIL TERM vs. PRAECIPE TO SETTLE, DISCONTINUE AND END WITH PREJUDICE TO REFILE DAWNA M KULBACKI Defendant 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#6041062 .« IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION FIA CARD SERVICES INC Plaintiff vs. Civil Action No. 08-1608-CIVIL TERM DAWNA M KULBACKI Defendant PRAECIPE TO SETTLE DISCONTINUE AND END WITH PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR: Settle, Discontinue and End the above-captioned matter upon the records of the Court prejudice to refile and mark the costs paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: Attorney for ain 'ff ly 00 Koppe Bui ing 436 Sevent Ave e Pittsburgh PA 1 219 (412) 434 7955 SWORN TO AND SUBSCRIBED before me this-/7 day 008 of tllcC , 2 N RY Lco?onrmrEa.T+ of PENNsnvANK NOMM Sed .Iennftr M. Swamm. Nobly Pubk Clly of Pftbwo, Allepl" County Cam"do on Feb. 22,2012 mow, Anoaetlon a liolefles ? ?.+ ?? -x 3 t? ?? ?-r ....- = r- ?. ,`v ..?. ,.,? t?.? ..?.-, .?,?_ :=? _> .?.f