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Home My WebLink About08-4207 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: 4100 ? c vs. COMPLAINT IN CIVIL ACTION KATHERINE J BOLLENDORF 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 06806056 C A Pit ABR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. KATHERINE J BOLLENDORF Defendant Civil Action No 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: KATHERINE J BOLLENDORF 113 S 15TH ST CAMP HILL, PA 17011 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXXXXXX9363 . 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 June 20, 2008 , in the amount of $8776.22 . 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 Defendant , KATHERINE J BOLLENDORF INDIVIDUALLY , in the amount of $8776.22 with interest at the legal rate of 6.000 per annum from date of judgment plus attorneys' fees of $1000.00 , and costs. James Warmbrodt,42524 WELTM EINBERG & REIS CO., L.P.A. 436 S ven h Avenue, Suite 1400 Pitt urg PA 15219 (41 43 -7955 FAX. 41 -338-7130 06 060 6 C A Pit ABR This law firm is a debt collector att?mVing to collect this debt for our client and any information obtai+PY will be used for that purpose. CARD v0,0 ost Je'??6'12 _I Enter Amount Enclosed Below Payment Due Date $ t Q Q May 14, 2008 Please make check payable to Discover Card. Minimum Payment due includes a past due 15 SDSN6A01 0004546 amount of $1,816.00. KATHERINE BOLLENDORF Will your payment get to us on time;: Pay 113 S 15TH ST your bill online and your payment can be CAMP HILL PA 17011-5502 made to your account on the same day. Visit Discovercard.com/payments today. PO BOX 15251 Iloilo 111111u11 Address, e-mail or telephone change? Print change ins ace WILMINGTON DE 19886-5251 above, or go to Discovercard.com. Print your e-mail address to receive important Account information and special offers. 000001986458798064396087762200000000877622 Discover More Card Account Summary Closinq Date: Account number ending in 9363 ,Payment Due Date May 14, 2008 Minimum Payment Due $8,776.22 Credit Limit $12,000.00 Credit Available $0.00 Cash Credit Limit $0.00 Cash Credit Available $0.00 April 15, 2008 page 1 of 1 Previous Balance $8 776 22 Payments And Credits , . Purchases 0.00 Cash Advances + 0.00 Balance Transfers + 0.00 Finance Charges + 0.00 New Balance + 000 6 $8,776.22 Cashback Bonus® Opening Cashback Bonus Balance $ 000 New Cashback Bonus Earned + 0.00 Cashback Bonus Balance y Available to Redeem - - - $ 0.00 Casfback Baouif Anniveriary - - - - - - - - - - - - - - - - A o:oo- Date: December 15 How Can We Help You? For Account Inquiries, write to us at. Please have your Discover Card available. Discover More Card, PO Box 309,43 Manage your account online of Discowrcard.eom Salt Lake City, UT 84130 TDD Customer Service: 1-800-DISCOVER (1-800.347-2683) For assisttaaommsee revs se?d . Deaf): Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence. ;Information For You While we are permitted under the Cardmember Agreement to increase the APRs on your Account because your payment was late, we have chosen not to do $o 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 d efault Rate Plan section of the Cardmember Agreement for details. URN -I -MONSWA=? 14 - Finance Charge Summary Average Dai IY Daily Periodic Nominal ANNUAL P ER C NTAGE ANNUAL PE RCENTAGE Pe riodic Transaction e e Balances Rates , ? ES RATES RD S ANCE N pf current billing period: 15 days CHA C ?urchases $0 Cash Advances $0 0.07942% 28.99% F 28 99 $0 no previous billing period: 13 days 0.07942% 28.99% F . % $0 ne $O 'Purchases $0 0.07942% 28.99% F 28.99% The rates that aPPIY to your Account are eith er fixed or the may vary NI as noted above. VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unworn 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 # 6806056 KATHERINE J BOLLENDORF 6011002695519363 N (Aj 00 -r, SHERIFF'S RETURN - REGULAR CASE NO: 2008-04207 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS BOLLENDORF KATHERINE J STEPHEN BENDER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BOLLENDORF KATHERINE J the 2008 DEFENDANT , at 1930:00 HOURS, on the 30th day of July at 113 S 15TH ST CAMP HILL, PA 17011 KATHERINE BOLLENDORF 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 Service Affidavit Surcharge i/05/08 18.00 15.00 .00 10.00 .00 43.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 07/31/2008 WELTMAN WEINBERG REIS By : Deputy Sheriff of A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. KATHERINE J BOLLENDORF Defendant No. 08-4207-CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D.447437 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6806056 Judgment Amount $ 9,776.22 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. KATHERINE J BOLLENDORF Defendant TO THE PROTHONOTARY: Civil Action No. 08-4207-CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, KATHERINE J BOLLENDORF above named, in the default of an Answer, in the amount of $9,776.22 computed as follows: Amount claimed in Complaint $8,776.22 Interest from date of judgment at the legal interest rate of 6.00% per annum Attorney's fees $1,000.00 TOTAL $9,776.22 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, quire PA I.D.#47437 Welt?nan, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6806056 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A.,1400 Koppers Building, 436 7`" Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 113 S 15TH ST, CAMP HILL,PA 17011 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff KATHERINE J BOLLENDORF Defendant(s) IMPORTANT NOTICE TO: KATHERINE J BOLLENDORF 113 S 15TH ST CAMP HILL,PA 17011 Date of Notice: Q o5 WWR#: 06806056 ease # cl-'-!aca-C'1UIL t-FRn 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) 249-3166 BY: CC?1ul.?c-?r a WcowA,-" PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Case no: 08-4207-CIVIL TERM Plaintiff vs KATHERINE J BOLLENDORF 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, KATHERINE J BOLLENDORF 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, KATHERINE J BOLLENDORF is not in the military service. Further Affiant sayeth naught. AFF ANT 1 TO AND SUBSCRIBED in my presence this J y day D1 V-J!1/1-? COMMONWEALTH OF PENNSYLVANIA Notarial Seal Heidi J. Kelly, Notary Public City of Pittsburgh, Allegheny County My Commission Expires Nov. 4, 2008 Member, Pennsylvania Association of Notaries 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 r Department of Defense Manpower Data Center S Military Status Report } Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 EP-17-2008 13:30:20 Last Name First/Middle Begin Date Active Duty Status T Service/Agency BOLLENDORF KATHERINE 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. rte rA 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.defensel.ink.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: BZIVNFJTXBH https://www,dmde.osd.mil/scra/owa/scra.prc Select 9/17/2008 a0 V t. -zz -c cry r• IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 08-4207-CIVIL TERM KATHERINE J BOLLENDORF 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 (xx) Assumpsit Judgment in the amount of $9,776.22 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: IC • 10 PRO ONOTARY (OR DEPUTY) KATHERINE J BOLLENDORF 113 S 15TH ST CAMP HILL,PA 17011 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7t" Avenue, Pittsburgh, PA 15219 1-888-434-0085