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Home My WebLink About08-5089 I A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. CHAD E BUBB Defendant No : 08 sod I j LQ7"-? 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 06861248 C A Pit ABR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No CHAD E BUBB 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: CHAD E BUBB 607 E WINDING HILL RD MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXXXXXX6773 . 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 July 23, 2008 , in the amount of $6986.14 . 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 , CHAD E BUBB INDIVIDUALLY , in the amount of $6986.14 with interest at the legal rate of 6.0001 per annum from date of judgment plus attorneys' fees of $1000.00 , and costs. James C. rmbro t,42524 WELTMAN. INBERG & REIS CO., L.P.A. 436 Seve th Avenue, Suite 1400 Pittsbu gh, PA 15219 (412) 4-7 55 FAX: 4 2-3 8-7130 06861 48 A Pit ABR This law firm is a debt collector attemp i to collect this debt for our client and any information obtained 1 be used for that purpose. CARD Payment Due Date $ j cc r ` i z June 21, 2008 please make check payable to Discover Card. Minimum yment due includes a past due amount of $1,198.00. EXHIBIT 22 SLSN6A01 0006401 CHAD BUBB 607 E WINDING HILL RD MECHANICSBURG PA 17055-4901 Address, e-mail or telephone change$ Print change in space above, or go to Discovercard.com. Print your e-mail address to receive important Account information and special offers. Will your payment get to us on time2 Pay your bill online and your payment can be made to your account on the same day. Visit Discovercard.com/payments today. PO BOX 15251 Illrsnll,n a lr lrn l 111111,11 WILMINGTON DE 19886-5251 1 11111111111111 ill ill 1111111,irIll ,InlnlIll n161nIll nillnlot I 000001986458615110893069861400000000698614 Discover More Card Account Summary Closing Date: May 22, 2008 page 1 of 1 Account number ending in 6773 Previous Balance $6,986.14 Payment Due Date June 21, 2008 Payments And Credits 0.00 Minimum Payment Due $6,986.14 Purchases + 0.00 Credit Limit $5,000.00 Cash Advances + 0 00 Credit Available $0.00 Balance Transfers . + 0.00 Cash Credit Limit $0.00 Finance Charges + 0.00 Cash Credit Available $0.00 New Balance $6,986.14 Cashback Bonus® Opening Cashback Bonus Balance $ 0.00 New Cashback Bonus Earned + 0.00 Cashback Bonus Balance $ 0.00 ------ Available to Redeem--- ------ ----- $ -- ----0.00-- Cb3hback BOnusS i4nnivers6ly Date: September 22 How Can We Hel You? p 1. Visit Discovsr.com to par your b11 for no cost, view our latest Account information, earn and redeem rewards and more 'It's your choice - 3 ways to help 2. Call 1.8004)ISCOVER (347.2683) for fast, easy selhservice Please have your Discover Cord available. For TDD (assistance for hearing impaired) see reverse side options or to speak with a Customer Service Account Manager 3' Write us at Discover Cord, PO Box 30943, Salt Lake City, UT 84130 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 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 Cardmember Agreement for details. Finance Charge Summary Nominal Transaction Average Daily ANNUAL ANNUAL Periodic Fee Daily Periodic PERCENTAGE PERCENTAGE FINANCE FINANCE Balances Rates RATES RATES CHARGES CHARGES current billing period: 22 days Purchases $0 0.06573% 23.99% V 23.99% $0 none Cash Advances $0 0.06641% 24.24% V 24.24% $0 $0 previous billing period: 10 days Purchases $0 0.06573% 23.99% V 23.99% $0 none The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above. It 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. WWR # 6861248 CHAD E BUBB 6011002580676773 n C r~ r (f. ^K' PV cz? Y? c- v u? W a ?aa -n l 5 0 SHERIFF'S RETURN - REGULAR CASE NO: 2008-05089 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS BUBB CHAD E KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BUBB CHAD E the DEFENDANT at 1056:00 HOURS, on the 16th day of September, 2008 at 607 E WINDING HILL ROAD MECHANICSBURG, PA 17055 by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 36.00 Affidavit .00 Surcharge 10.00 1 u/040 00 6 Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 09/17/2008 WELTMAN WEINBERG REIS By A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. CHAD E BUBB Defendant No. 08-5089-CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE 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#6861248 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 08-5089-CIVIL TERM CHAD E BUBB Defendant PRAECIPE TO SETTLE DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE 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. By: Jam/gh, mbrodt, Esquire PA I1400 r s uilding 436 enue Pitts15219 (41255 WW 248 SWORN TO AND SUBSCRIBED before me this (33 day of DeCfXylkila- .2008 AR COMMONWEALTH OF _PENNSYLVANIA Notarial seal Jennifer M. Borowski, Notary Public City of Pittsburgh, Allegheny County M Commission Ex ires Feb. 22, 2012 Member, Pennsylvania Aasociation of Notaries