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HomeMy WebLinkAbout04-0752IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. JACQUELYN CASTNER Defendant COMPLAINT IN CIVIL ACTION 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. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03302185 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. JACQUELYN CASTNER Defendant Civil Action No. ~t- Q,~' ~ COMPLAINT IN CIVIL ACTION 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 LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 (717) 249-3166 COMPLAINT Plaintiffis a corporation with offices at 3311 Mill Meadow Drive, Hilliard, OH 43026. 2. Defendant is an adult individual residing at 32 Farm House Lane, Camp Hill, PA 17011. 3. Defendant applied for and received a credit card issued by Plaintiff's bearing the account number 6011 0029 6953 4189. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of February 12, 2004, in the amount of $3,427.21. 5. Defendant is in default of the terms of the cardholder Agreement having not made monthly payments to Plaintiffthereby rendering the entire balance immediately due and payable. 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 principal balance, finance charges or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, Jacquelyn Castner individually, in the amount of $3,427.21 with interest at the legal interest rate of 6% per annum from date o f judgment plus attorneys' fees of $500.00, and costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. PA I.D. #47437 WELTMAN, WE1NBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#:03302185 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unswom falsifications to authorities, that he/she is ~oborv .~dk i n s Accounts ManaRer of Discover Financial Services Inc., servicing agent of the plaintiffherein, that (Title) (Company) he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Complaint are tree and correct to the best of his/her knowledge, information and belief. (Signature) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. JACQUELYN CASTNER Defendant No. 04-752 CIVIL TERM pRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. ff47437 WELTMAN, WEINBERG & REIS CO., LP.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03302185 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. JACQUELYN CASTNER Defendant Civil Action No. 04-752 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUF AND END WITHOUT PREJUDICE TO REFII. F 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. SWORN TO AND SUBSCRIBED Attorr~ey Tor P~a~n "t~-~~ 2718 Koppers Buildir',g' 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03302185 before me this f'~ day Wendy L ~ ~ , NOTARY PUBLI~' ~ ......