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Home My WebLink About08-2200 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. BRYN A COCHRAN Defendant No : n$ - 2dm Civil Ter" 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 06558025 C A Pit SXA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION 4 DISCOVER BANK Plaintiff VS. Civil Action No BRYN A COCHRAN 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: BRYN A COCHRAN 500 GENEVA DR APT F8 MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXXXXXX2724 . 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 March 18, 2008 , in the amount of $7702.21 . 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 I 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 , BRYN A COCHRAN INDIVIDUALLY , in the amount of $7702.21 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 'Warmbrodt,42524 WELT EINBERG & REIS CO., L.P.A. 436 Se e th Avenue, Suite 1400 Pitts r h, PA 15219 (412) 4 4-7955 FAX: 4 1/2-338-7130 0655 7 C A Pit SXA This law firm is a debt collector attentpting to collect this debt for our client and any information obtained will be used for that purpose. D New Balance Minimum Payment Due Account Number ending in 2724 DISCOVER EAR $0.00 $1,594.00 Enter Amount Enclosed Below C -- - - Payment Due Date February 28, 2008 , 31 SDSN6A01 0007142 BRYN COCHRAN Know what's on your statement-before you 500 GENEVA DR APT F8 even get it. Keep track online with daily updates and up to 12 months of history. Visit MECHANICSBURG PA 17055-6682 Discovercard.com/register PO BOX 15251 ???rru??uurur??ruuu??u??rr? WILMINGTON DE 19886-5251 Address, e-mail or telephone change? Print change in space ?rru???r?ur?n?u? above, or go to Discovercard.com. Print your e-mail address to receive important Account information and special offers. 000006011002040452724000000000000000159400 Discover More Card Account Summary Closing Date: January 31, 2008 page 1 of 1 Account number ending in 2724 Previous Balance $7,702.21 Payment Due Date February 28, 2008 Payments And Credits 7,702.21 Minimum Payment Due $1,594.00 Purchases + 0.00 Credit Limit $5,000.00 Cash Advances + 0.00 Credit Available $0.00 Balance Transfers + 0.00 Cash Credit Limit $1,300.00 Finance Charges + 0.00 Cash Credit Available $0.00 New Balance $0.00 Cashback Bonus® Opening Cashback Bonus Balance $ 0.00 New Cashback Bonus Earned + 0.00 Cashback Bonus Balance $ 0.00 Cashback Bonus® Anniversary - -- - - - - - _ - - - - - - - - - - Avai-ktble to Redeem Dole: March 6 How Can We Help You? For Account Inquiries, wrile to us at. Discover More Carl, PO Box 30943 Please have your Discover Card available. Salt Lake City, UT 84130 Manage your account online at Discovercard.com TDD (Telecommunications Device for the Deo: Customer Service: 1.8004DISCOVER (1-800-347-2683) For assistance, we reverse side. Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence. Trans. Post Date Payments and Credits Jan 31 Jan 31 INTERNAL CHARGE-OFF $ .7,702.21 EXHIBIT 4-1 Finance Charge Summary Average Daily Nominal Transaction ANNUAL ANNUAL Periodic Fee Daily Periodic PERCENTAGE PERCENTAGE FINANCE FINANCE Balances Rates RATES RATES C14ARGFS CWARMq current billing period: 25 days 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 # 6558025 BRYN A COCHRAN 6011002040452724 N orl Y'7l r? J W .r E ? m w?i y3 D iY r rv rn c 0 SHERIFF'S RETURN - REGULAR CASE NO: 2008-02200 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK COCHRAN BRYN A VS MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE COCHRAN BRYN A was served upon the DEFENDANT at 1902:00 HOURS, on the 16th day of April , 2008 at 500 GENEVA DRIVE APT F8 MECHANICSBURG, PA 17055 BRYN COCHRAN 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 14.00 Postage ,58 Surcharge 10.00 (? 00 y/?2 S/D Y ?" 42.58 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 04/17/2008 WELTMAN WEINBERG REIS By. puty r' f A. D. .1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. BRYN A COCHRAN Defendant No. 08-2200-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#6558025 Judgment Amount $ 8,702.21 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. w IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 08-2200-CIVIL TERM BRYN A COCHRAN Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, BRYN A COCHRAN above named, in the default of an Answer, in the amount of $8,702.21 computed as follows: Amount claimed in Complaint $7,702.21 Interest from date of judgment at the legal interest rate of 6.00% per annum Attorney's fees $1,000.00 TOTAL $8,702.21 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: William T. Molczan squire PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6558025 Plaintiffs 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: 500 GENEVA DR APT F8, MECHANICSBURG,PA 17055 'a IN THE COURT OF COMMON PLEAS CUMBERLAND.COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff case # 05 - m)D-Q Q -C\vtl- 1 C. O) BRYN A COCHRAN Defendant(s) IMPORTANT NOTICE TO: BRYN A COCHRAN 500 GENEVA DR APT F8 MECHANICSBURG,PA 17055 Date of Notice: W-23108 WWR#: 06558025 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 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 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) 249-3165 BY: / hOlmtkA PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A, 1400 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, oA 15219 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. BRYN A COCHRAN Case no: 08-2200-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, BRYN A COCHRAN 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, BRYN A COCHRAN is not in the military service. Further Affiant sayeth naught. COMMONWEALTH Or PENNSYLVANIA 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. AFFIANT SWORN TO AND SUBSCRIBED in my presence this ? day of 2?5.. Notarial Seal Wendy L. Gault, Notary Public NOT RY PUBLIC City Of Pittsburgh, Allegheny County My Commission E.xi?ires .fuly 15, 2010 Member, Pennsylvania Association of Notaries Request for Military Status Page JUL-07-2008 13:11:28 Department of Defense Manpower Data Center 40 Military Status Report Pursuant to the Servicemembers Civil Relief Act < Last Name First/Middle Begin Date Active Duty Status Service/Agency COCHRAN BRYN 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. y6t 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/faq/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:BRGNDXSSXRC https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 7/7/2008 F IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 08-2200-CIVIL TERM BRYN A COCHRAN Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order r J dgment was entered against you on ( 2,(o$ (xx) Assumpsit Judgment in the amount of $8,702.21 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: 114 PPRC.A ONOTA BRYN A COCHRAN 500 GENEVA DR APT F8 MECHANICSBURG,PA 17055 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7 b Avenue, Pittsburgh, PA 15219 1-888-434-0085 4 t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. BRYN A COCHRAN Defendant MARQUETTE SAVINGS BANK, Garnishee, No. 08-2200-CIVIL TERM PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) 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 Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6558025 i - L IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 08-2200-CIVIL TERM BRYN A COCHRAN, 50o Geneva br, Ap-f F8 Mesh, PA 17055 Defendant MARQUETTE SAVINGS BANK, U0 PEAPIN sreEaT ERIE, PA 1(0501 Garnishee PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of ERIE County: 2. against BRYN A COCHRAN, Defendant 3. against MARQUETTE BANK, Garnishee 4. Judgment Amount Less payments of Interest Costs SUBTOTAL: Costs (to be added by Prothonotary): $ 8,702.21 650.00 $ 494.36 $ 8,546.57 WELTMAN, WEINBERG & REIS CO., L.P.A. By:L/,i74/"L-? William T. MolcAn, Esquire PA I.D. 447437 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6558025 ALE ._? E 2009 OCT 1 6 PH 2: 14 M4.50 pQ A-nY Q .5a eaF 178.50 -%I tod .08 - PD A-rn 4(2.00 bueCro .50 I. L sq i acoS4 23a164 Erie O.,oon4tl LL Of & 4*"-Oj WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 08-2200 Civil CIVIL ACTION - LAW TO THE SHERIFF OF ERIE COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From BRYN A. COCHRAN, 500 Geneva Drive, Apt. F8, Mechanicsburg, PA 17055 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of GARNISHEE(S) as follows: MARQUETTE SAVINGS BANK, 920 Peach Street, Erie, PA 16501 and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $8,052.21 Interest -- $494.36 Atty's Comm % Atty Paid $162.08 Plaintiff Paid Date: 10/16/09 L.L. $.50 Due Prothy $2.00 Other Costs (Seal) REQUESTING PARTY: By: Name WILLIAM T. MOLCZAN, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO, LPA 1400 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Deputy Supreme Court ID No. 47437 WELTMAN, WEINBERG & REIS CO., L.P.A. BY: James C. Warmbrodt, Esquire I.D. No.42524 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 Phone: 412.434.7955 Fax: 412.434.7959 File # 06558025 Attorney for Plaintiff(s) DISCOVER BANK vs. BRYN A COCHRAN and MARQUETTE BANK Garnishee(s) CUMBERLAND County Court of Common Pleas NO. 08-2200-CIVIL TERM PRAECIPE TO DISCONTINUE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly marked the above matter settled, discontinued, and ended as to Garnishee(s), MARQUETTE BANK, only. WELTMAN, WEINBERG & REIS CO., L.P.A. By James. Warmbrodt, Esquire Attorn for Plaintiff Sworn to and subscribed Before me the95'Day of November, 2009 ///Z, OTARY PUBLIC COMMONWEALTH OF PENNSYLVANIA Notarial Seal Sheila Q. Bevan, Notary Public City Of Pittsburgh, Allegheny County My Commission Expires Nov. 15, 2010 Member, Pennsylvania Association of Notaries FJLED-431l l(-;E OF THE" PR07,,NIO ARY 20114 DEC 15 Ali 11: 11 CUmt-L. .: ,j-,UNTY PEENI ,c3YLVANIA tv-m pa Ayrq ox* 43q 11 *7 U U4,R 550.u. r F; , rLl J \??.. rG AN2f "i v Cuv' NT P[ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. BRYN A COCHRAN Defendant(s) No. 08-2200-CIVIL TERM 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#6558025 DIS 4t, oo PO Arry av-* 43&55/&`1 P -t-13(og87 . jW .. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 08-2200-CIVIL TERM BRYN A COCHRAN 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: Tames C. W? PA I.D. # 42 Esquire WELTMA EINBERG & REIS CO., L.P.A. 1400 Kop ers uilding 436 Sev th venue Pittsbu h A 15219 (412) 4 -7999 WWR #6558025 Sworn to and subscribed before me this 30 day of December, 09 ARY PTT BLIC _C0ViU!CN"VVf_ALTH CF i TFNN 'vLV' '1'1A S'G. r? my Of i , "Y My Commission 15, Member Nnnsvlvania Association of t