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Home My WebLink About08-5348IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff NO= ~g - 53t~$ ~~~~~ ~ertN vs. COMPLAINT IN CIVIL ACTION ERIC-PAUL JOHNSON 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 06919687 C A Pit ABR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No ERIC-PAUL JOHNSON 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: ERIC-PAUL JOHNSON 1620 VALLEY RD MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXX2807 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 August 27, 2008 in the amount of $16359.35 . 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 $1500.00 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 ERIC-PAUL JOHNSON ,INDIVIDUALLY in the amount of $16359.35 with interest at the legal rate of 6.000 per annum from date of judgment plus attorneys' fees of $1500.00 and costs. ~ - James C. armbrodt_,42524 WELTM?,l~T INBERG & RE I S CO . , L . P . A . 436 Se ent Avenue, Suite 1400 Pitts rg PA 15219 (412) 43 -7955 FAX: 41 -338-7130 069 96 C A Pit ABR This law firm is a debt collector atte ing to collect this debt for our client and any information obtaine will be used for that purpose. VIJ%.~~'r LI< CARS 50.00 " 52,787.00 Payment Due Date June 29, 2008 30 SDSN6A010002859 ERIC-PAUL JOHNSON 1620 VALLEY RD MECHANICSBURG PA 17055-4854 Address, o-mail or telephone change$ Print change ins ce above, or go to Discovercard.com. Print your o-mail add ess ro receive important Account information and special offers. Enter Amount Enclosed Below #, ~.-;y Will your payment get to us on time$ Pay your bill online and your payment can be made to your account on the same day. Visit Diseovercard.com/payments today. PO BOX 15251 I)~~~~~I~rrr~~l~~lr~rlr~~ll WILMINGTON DE 19886-5251 ~ui~~~i~n~n~~~n~u~~n~~i~ni)i~i~~)nu))i~i~nn~~~~~n~ 0000019864589253186240.x]0000000.000000278700 Discover More Card Account Summary Closing Da-e: May 30, 2008 page 1 of 1 Account number ending in 2807 Previous Balance $16,359.35 Payment Due Date June 29, 2008 Payments And Credits - 16,359.35 Minimum Payment Due $2,787.00 Purchases + 0.00 Credit Limit $15,002.00 Cash Advances + 0,00 Credit Available $0.00 Balance Transfers + 0.00 Cash Credit Limit $6,100.00 Frennes C6nrgea + 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 - Available to Redeem $ _ D.00 Dare: May 23 .How Can We Hel You? P ' . visit Di"ewr.can ro pay your bil Fa "° test, view ur latest Account information, earn and redeem rewardsoand more It's your choice - 3 ways to help 2. Call 1-BOO.DISCOVER (347-2683) for fast, easy self-service Please have your Discover Card available. options or fo speak with a Customer Service Account Manager For TDD (assistance for hearing impaired) see reverse side 3. Write us at Discover Card, PO Box 30943, Sah Lake City, UT 84130 Transactions SO Fraud Liabiliy Guarantee Use your Discover Card with confidence. Trans. Post Date Dais Payments and Crodits May 31 May 31 INTERNAL CHARGE-OFF $ -16,359.35 EXHIBfT finance Charge Summary Nominal Transaction Average Daily ANNUAL ANNUAL Periodic Fee Daily Periodic PERCENTAGE PERCENTAGE FINANCE FINANCE B n Rants RATES RATES CHARGES CHARGES current billing period: 8 days Purchases $0 0.02737% 9.99% F 9.995'0 $0 none Cash Advances $0 0.06025% 21.99% F 21.995'0 $0 $0 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 unsworn falsifications to authorities, that he is Robert Adkins (Name) Accounts Manager of DFS Services LLC ,plaintiff herein, that (Title) (Company) he 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 knowledge, information and belief. (Signature) WWR # 6919687 ERIC-PAUL JOHNSON 6011002810762807 ~ c-;j ~f 7 ~. C.~ '~ a ~' f., 7 ~~ ~ ., . W }'S t~ 7 v _ ~. ' ' r ' 1'~~ V ~' - ~ „) f .7 '. i J ~~ f W ! 7 li I~•Of 2010 FEB -~ ~! ~ ! $ p8~it~.VA1~A IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 08-5348 CIVIL TERM vs. PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE ERIC-PAUL JOHNSON Defendant(s) FILED ON BEHALF OF Plaintiff COl1NSEL OF RECORD OF THIS PARTY: .lames C. Warmbrodt, Esquire PA LD. #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#6919687 DIS IN THE COURT' OF COMMON PLEAS CUMBERLAND COUN"I'Y, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 08-5348 CIVIL, TF,RM Defendant(s) PRAECLPE TO SETTLE DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE ERIC-PAUL JOHNSON TO THE PROTHONOTARY OF Cumberland COUNTY: SIR: Kindly settle, discontinue and end without prejudice to refile the above-captioned matter upon the records of the Court and mark the costs paid. WELTMAN, WEINBERG &REIS CO., L.P.A. By: James C. Warmbc t, Esquire PA LD. #42524 WELTMAN, I BERG &REIS CO., L.P.A. 1400 Koppers u' ding 436 Seventh v nue Pittsburgh, 15219 (412)434- 5 SWORN TO AND SUBSCRIBED COMMONWEALTH F PENNSYLVANIA NotaAal 8esl Wayne A. Jar-ws, Notary Publks City of Plttsburph. AN1~phsny County My Commhsbn JurN 20, 2010 Member, Pennsylvania Aasodat~n of Notaries before me this ~ day