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Home My WebLink About08-4336, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. KAREN C FINK No : 0,9- t-/33 G ? l ??^ COMPLAINT IN CIVIL ACTION Defendant FILED ON BEHALF OF Plaintiff i COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS 436 Seventh Avenue, Suite Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 06737189 C A Pit ABR CO., L.P.A. 1400 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. KAREN C FINK Defendant No. G7- v33G COQ `TZ, 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 06737189 C A Pit ABR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. KAREN C FINK Defendant Civil Action No Q F,_ y 3 3 (-- Gju 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: KAREN C FINK 302 STONEHOUSE RD CARLISLE, PA 17015 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number_ XXXXXXnXXXXXXXXX0795 . 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 May 28, 2008 , in the amount of $2370.16 I 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 $300.00 . 8. Although repeatedly requested. to clo 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 , KAREN C FINK INDIVIDUALLY , in the amount of $2370.1.6 with interest at the -legal rate of 6.000% per annum from date of judgment plus attorneys, fees of $300.00 , and costs. James C Warmbrodt,42524 WELT WEINBERG & REIS CO., L.P.A. 436 ev th Avenue, Suite 1400 Pit sbu gh, PA 15219 (4 2) 4 4-7955 F .: 4 2-3318-7130 0 737 F',.9 CA Pit ABR I'h.is law firm is a debt collector alem ting to collect this debt for our client and any information obtane will be used for that purpose. • 6 %WV*OT s=s% vl,.ri 6. IV 14A,iii1V.,ii CARD ! omen nnrwrn urcwseru ovtuw Payment Due Date $ April 21, 2008 Please make check payable to Discover Card. Minimum ppaayyment due includes a past due amount of 5517.00. 22 SDSN6A01 0005288 KAREN FINK Will your payment get to us on time? Pay 302 STONEHOUSE RD your bill online and your payment can bs CARLISLE PA 17015-9429 made to your account on the same doy. Visit DieCOVercard.com/payments today. PO BOX 15251 Address, e-mailor tel WILMINGTON DE 19886-5251 above, or go to Discovver?com.Pint Print your"oil in address to IIf Iiloll nIIIIis III ifill IIII receive important Account information and special offers. 000001486458450720970023701600000000237016 Discover More Card Account Summary Closing Date: March 22. 2008 Account number ending in 0795 Payment Due Date April 21, 2008 Minimum Payment Due $2,370.16 Credit Limit $1,700.00 Credit Available $0.00 Cash Credit limit $0.00 Cash Credit Available $0.00 page 1 of 1 Previous Balance $2 370.16 Payments And Credits , Purchases 0.00 Cash Advances + 0.00 Balance Transfers + 0.00 Finance Charges + 0.00 New Balance + 000 $2,370.16 Cashback Bonus® Opening Cashback Bonus Balance $ 000 New Cashback Bonus Earned + 0.00 Cb3hbock RonuO Anniversary Cashba& Bonus Balwe* $ 0.00 Available-to Redeem- Date: October 22 0.00 - How Can We Help You? Fa Acc«Mt Inquiries, write to us at. Please haw your Discover Card available Discover More Card, PO Box 30943 . Manage your account online at Discovereard.eom Salt Lake City, UT 84130 Customer Service: 1.800-DISCOVER (1-800.347-2683) TDD (Fefeeemnwnicalions Drake For da Deaf): For assistance, see reverse side. Transactions $0 Fraud Liability Guor=tes Use our Disc C d y over ar 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 so 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 date. See the Default Rate Plan section of the Cordmember Agreement for details. EXHIBIT Finance Charge Summary Nominal Transaction Average Dai y Daily dic PEANNUAL ANNL Periodic RCENTAGE RATES EN AGE FINANCE FFINANCE @9190543 Rates RATES QMR AGES current billing period: 22 days Purchases $0 0.07942% 28.99% F 28.99% Cash Advances $0 0.07942% 28,99% F .28.99% $0 none previous billing period: 2 days $0 $0 Purchases $0 0.07942% 28.99% F 28.99% $0 none 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 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 # 6737189 KAREN C FINK 6011002330340795 ..,? C= q Fn _q Ull ... + -13 ° -21 (?' /pI ' _ V •Q Q? V IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. KAREN C F1? at t. Defs No. 08-4336-CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END WITH PREJUDICE 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#6737189 1e: ?'????t,... . f ti k IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 08-4336-CIVIL TERM KAREN C FINK Defendant PRAECIPE TO SETTLE AND DISCONTINUE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR: Please kindly Settle and Discontinue the above-captioned matter upon the records of the Court and mark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C PA I.D.# 1400 Kol 436 Sew Pittsbur (412) 4,8d Esquire Ilding nue 15219 189 SWORN TO AND SUBSCRIBED -f-In before me this day of 2008 N ARY P It COMMONWEALTH OF PENNSYLb;1NIA Notarial Seal WaYne A. Jones, Notary Public ?Y Of Pitts burgh, Allegheny County Y Commiss+r,)r•. . i ?'irPS June 2g9, ,2010 Member, n_ "h" "f Notaries m fr, ? G 1 nl? f1 , ` 1.I ,. ^1 f ? J r ? r SHERIFF'S RETURN - REGULAR CASE NO: 2008-04336 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS FINK KAREN C MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon FINK KAREN C the DEFENDANT , at 0020:49 HOURS, on the 5th day of August , 2008 at 302 STONEHOUSE RD CARLISLE, PA 17015 DEFENDANT 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 8.00 Affidavit SIa?Og .00 Surcharge 10.00 Sworn and Subscibed.to before me this day So Answers: R. Thomas Kline 08/06/2008 WELTMAN WEINBERG & REIS By: D e p i f f of A. D.