The URL can be used to link to this page

Home My WebLink About08-1610 l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: p$- 1610 Civi l Tern, vs. COMPLAINT IN CIVIL ACTION DONNA HOFFMAN 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 06129331 C A Pit WLG IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No DONNA HOFFMAN 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 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: DONNA HOFFMAN 550 SAINT JOHNS DR CAMP HILL, PA 17011 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXXXXXX0756 . 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 $3583.86 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 . VIJ%.1twyY CK CARD 17 SDSN6A01 0006256 HOFFMAN, DONNA 550 SAINT JOHNS DR CAMP HILL PA 17011-1332 $642.00 Enter Amount Enclosed Below Payment Due Date $ 1 August 16, 2006 Please make check payable to Discover Card. You are overlimit. Pay the sum of the monthly minimum payment plus the overlimit amount of $1,083.86. 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. 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. PO BOX 15251 1111111 loll III1111111loll II WILMINGTON DE 19886-5251 1n111111r,1u1all III 11111111111111111111loll IIIII ,r,11111n1 000006011298600950756035838600000000064200 Discover Card Account Summary Closing Date: July 17, 2006 page 1 of 1 %ccount number ending in 0756 Payment Due Date August 16, 2006 Minimum Payment Due $642.00 Credit Limit $2,500.00 Credit Available $-1,083.00 Cash Credit Limit $600.00 Cash Credit Available $0.00 Previous Balance $3,425.45 Payments And Credits 0.00 Purchases + 78.00 Cash Advances + 0.00 Balance Transfers + 0.00 Finance Charges + 80.41 New Balance $3,583.86 You may be able to avoid Periodic Finance Charges, see the reverse side for details. Cashback Bonus® Opening Cashback Bonus Balance $ 0.00 New Cashback Bonus Earned + 0.00 Cashback Bonus Balance $ 0.00 Cashback Bonus®-Anniversary- - - - - - - - - - - - - - • -- -- Avoila6le.to. Redeem- $- - - - - - -OAO- - .. - - bate: October 17 How Can We Help You? For Account Inquiries, write to us at, Please have your Discover Card available. Discover Card, PO Box 30943 Salt Lake City, UT 84130 Manage your account online at Discowrcard.com TDD (Telecommunications Device for the Deaq: 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. Trans. Post Date Date Other/Miscellaneous Jul 17 Jul 17 OVERLIMIT FEE $ 39.00 Jul 17 Jul 17 LATE FEE 39.00 Information For You 7 Jr A Sho confident) Your Discover(R) Card has you covered w p y Complet raud Protection for your peace of mind. With our advanced fraud warnings, you'll know right away if any suspicious act' it-occurs. And if someone makes fraudulent charges with your card, our $0 Fraud liability guarantee means you'r,. respe-AAr, '° Check out Shop Discover Card at Diseovercard.com/shop for discount offers From your Favorite online retailers Finance Charge Summary Average Daily Nominal ANNUAL ANNUAL Periodic Transaction Fee Daily Balance s Periodic Rates PERCENTAGE RATES PERCENTAGE RATES FINANCE CHARGES FINANCE CHARGES ,current billing period: 30 days Purchases $3464.16 0.0773711a 28.24% V 28.24% $80.41 none Cash Advances $0 0.07737% 28.24% V 28.24% $0 $0 The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above 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# 6129331 DFS# 60112986009507569 ?' C 3 ov? SHERIFF'S RETURN - REGULAR CASE NO: 2008-01610 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS HOFFMAN DONNA 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 HOFFMAN DONNA the DEFENDANT , at 1700:00 HOURS, on the 27th day of March , 2008 at 550 SAINT JOHNS DRIVE CAMP HILL, PA 17011 DONNA HOFFMAN 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 Service 18.00 12.48 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 40.48,--03/28/2008 WELTMAN WEINBERG REIS Sworn and Subscibed to By: before me this day Deputy S riff of A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION e DISCOVER BANK Plaintiff VS. DONNA HOFFMAN Defendant No. 08-1610-CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT 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. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6129331 Judgment Amount $ 4,083.86 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. A IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 08-1610-CIVIL TERM DONNA HOFFMAN Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, DONNA HOFFMAN above named, in the default of an Answer, in the amount of $4,083.86 computed as follows: Amount claimed in Complaint $3,583.86 Interest from date of judgment at the legal interest rate of 6.00% per annum Attorney's fees $500.00 TOTAL $4,083.86 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. By: MatkewD. b an, Esquire PA I.D.#90963 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6129331 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: 550 SAINT JOHNS DR, CAMP HILL,PA 17011 . IN THE COURT Or' COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff DONNA HOFFMAN Defendant(s) IMPORTANT NOTICE TO: DONNA HOFFMAN 550 SAINT JOHNS DR CAMP HILL,PA 17011 Date of Notice: _ (35 I WWR#: 06129331 Case # (18- IU kQ C w IEF-m YOU ARE IN DEFAULT BECAUSE YOU HAVE FAI.?ED TO ENTER A WRITTEN APPEARANCE PERSONALLY.OR BY ATTORNEY AND FILI3 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 YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR 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 TAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, `PHIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED F;7 OR NO FEE. 1 LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 BY: ?(? - aw ao bb OCR vwc PATRICK THOMP.r? WOODMAN PA I.D. #34507 WELTMAN, WEIN:3ERG & REIS CO., L.P.A. 1400 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, P.," 15219 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. DONNA HOFFMAN Defendant Case no: 08-1610-CIVIL TERM NON-MILITARY AFFIDAVIT 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, DONNA HOFFMAN 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, DONNA HOFFMAN is not in the military service. Further Affiant sayeth naught. A IANT SWORN TO AND SUBSCRIBED in my presence this " day of ?_l V1 COMMONWEALTH OF PENNSYLVANIA NotedN Sed JennBer M. Borowski, Notary Pubft NO CWr of PWjburQjN AAM Mny County commission Exores Feb. 22.2012 Member, Pennsylvania Aswdelbn of Ndarisa 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 Page 1 of 1 Department of Defense Manpower Data Center JUN-18-2008 06:50:43 Last Name First/Middle Begin Date Active Duty Status Service/Agency HOFFMAN DONNA Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Military Status Report Pursuant to the Servicemembers Civil Relief Act 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. 41N? OVA 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 dirty 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: htt . -nw m.defenselink.mil/faq/i)is/PC09SLDR.htm1 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: SLBXFDNGMI https://v;w,,v.dmdc.osd.mil/scra/owa/scra.prc-Select 6/18/2008 -7r?, , -- IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 08-1610-CIVIL TERM DONNA HOFFMAN Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judgment was entered against you on 1,427109 (xx) Assumpsit Judgment in the amount of $4,083.86 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 ONOTAR EP TY) DONNA HOFFMAN 550 SAINT JOHNS DR CAMP HILL,PA 1.7011 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7th Avenue, Pittsburgh, PA 15219 1-888-434-0085