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Home My WebLink About08-5350IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK, Plaintiff VS. BRADLEY WENDEL GLUNT, Defendant No. pa- &W Civol -P-;r0t COMPLAINT IN CIVIL ACTION 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#6858446 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK, Plaintiff vs. Civil Action No. BRADLEY WENDEL GLUNT, Defendant 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 fling 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 ROAD, NEW ALBANY, OH 43054. 2. Defendant is an adult individual residing at the address listed below: BRADLEY WENDEL GLUNT 983 BIG SPRING RD SHIPPENSBURG,PA 17257 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXX9513 4. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of JULY 31, 2008 in the amount of $1,664.33. A true and correct copy of Plaintiff's Statement of Account is attached hereto, marked as Exhibit "1" and made a part hereof 5. Defendant is in default of the terms of the cardholder Agreement having not made monthly payments to Plaintiff thereby 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 $300.00. 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, BRADLEY WENDEL GLUNT, individually, in the amount of $1,664.33 with interest at the legal interest rate of 6% per annum from date of judgment plus attorneys' fees of $300.00, 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. James C. brodt, Esquire PA I.D. 42 24 WELT A , WEINBERG & REIS CO., L.P.A. 1400 op ers Building 436 ev th Avenue Pi b gh, PA 15219 (4 434-7955 ?..Aw • 116s111, -" • -r vws I Account Number ending in 9513 CARD $0.00 3741-00. $ _ J 74.00 Enter Amount Enclosed Below Payment Due Date June 29, 2008 30 W vdA01 0001658 BRADLEY GLUNT Will our 983 BIG SPRING RD payment get to us on time? Pay SHIPPENSBURG PA 17257-9753 Your ill online and your payment can be made to your account on the same day. Visit Diseovereard.com/payments today. PO BOX 15251 Address,e-mail or telephone chanq0 Print ppoo WILMINGTON DE 19886-5251 above, or go to Discovercard com. print your eail in address to )nnO( (u)n(n?n?n??m(n?un(n(n?r(uu)(n(n?un?(?n?n( receive important Account information and special offers. 000001986458124454865000000000000000037400 Discover More Card Account Summary Account numb er d Closing Date; May 30, 2008 n e ing in Payment Due Date 9513 June 29, 2008 Minimum Payment Due $374.00 Credit Limit $3,500.00 Credit Available $0.00 Cash Credit Limit $900.00 Cash Credit Available $0.00 page 1 of 1 Previous Balance Payments And Credits $1,664.33 Purchases 1,664.33 Cash Advances + 0.00 Balance Transfers + 0.00 Finance Granges + 0.00 New Balance + 000 = $0.00 Cashback Bonus* O pening Cashbock Bonus Balance New Cashback Bonus Earned $ 0'00 Cashbazk Barrus® Anniversary - Coshbadc Bonus Balance $ 0.00 -- - - - Available to Redeem Date: August 4 - - - 0.00- How Can We Help You? 1 • Visit Discovereem to Mfrs your choice - 3 ways to hel at, our latest Account informatpay ion, for no review and mo 2 C l p Please have your Discover Card available re . o l 1-800-DISCOVER (347-2683) for fast, easy sellLservice options or to speak with a Cu t . s omer Service Account Manager For TDD (assistance for hearing impaired) see reverse side 3. Write us at Discover Card, PO Box 30943, Salt Lake City, UT 84130 Transactions $0 Fraud Liability Guarantee U Wis. P se your Discover Card with confidence. Dale Payrn enb and Credits May 31 May 31 INTERNAL CHARGE-OFF $ -1,664.33 EXHIBIT Finance Charge Summary. Nominal Average Daily B°lane Daily Periodic ANNUAL P SNTAGf ANNUAL CEMA Periodic Pf Transaction Fes l3 billing period; 27 d Bates TE ? QMRM FINANCE ays - Purchases s0 Cash Advances $0 0.07942% 28.99'X, F $0 The rates that apply to your Acc t 0.07942% 28.99% F ry 28.99% none oun are eithe r fixed (F) or they m va N) 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/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 # 6858446 BRADLEY WENDE GLUNT 6011002080389513 J OS1 z ? ? $ a LA i 7 co `.} ;? C.! i C3 SHERIFF'S RETURN - REGULAR CASE NO: 2008-05350 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS GLUNT BRADLEY WENDEL NOAH CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE GLUNT BRADLEY WENDEL was served upon the DEFENDANT , at 1200:00 HOURS, on the 12th day of September, 2008 at 983 BIG SPRING RD SHIPPENSBURG, PA 17257 by handing to MARY GLUNT, MOTHER 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 It'161101 9, 18.00 12.00 .00 10.00 .00 40.00 Sworn and Subscibed to before me this day So Answers: ? ? R. Thomas Kline 09/15/2008 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. No. 08-5350-CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT BRADLEY WENDEL GLUNT Defendant 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. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6858446 Judgment Amount $ 1,964.33 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. BRADLEY WENDEL GLUNT Defendant TO THE PROTHONOTARY: Civil Action No. 08-5350-CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, BRADLEY WENDEL GLUNT above named, in the default of an Answer, in the amount of $1,964.33 computed as follows: Amount claimed in Complaint $1,664.33 Interest from date of judgment at the legal interest rate of 6.00% per annum Attorney's fees $300.00 TOTAL $1,964.33 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, Es*ire PA I.D.#47437 d Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6858446 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A.,1400 Koppers Building, 436 7a' Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 983 BIG SPRING RD, SHIPPENSBURG,PA 17257 14,+1 1 . IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff BRADLEY WENDE GLUNT Defendant(s) IMPORTANT NOTICE TO: BRADLEY WENDE GLUNT 983 BIG SPRING RD SHIPPENSBURG,PA 17257 Date of Notice: 101231% WWR#: 06858446 Case # Q - 531'0 ' (1? tomq 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 : _?cfM?U4 (q PATRICK THOMAS WOOD PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 (412) 434-7955 hh a. IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs BRADLEY WENDEL GLUNT Case no: 08-5350-CIVIL TERM 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, BRADLEY WENDEL GLUNT 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, BRADLEY WENDEL GLUNT is not in the military service. Further Affiant sayeth naught. !! ?/A - AFFIA T SWORN TO AND SUBSCRIBED in my presence this ( day of N.NIrm"C ZI;;;- M. BonDwSki, Ptpdry L2012 NO7 Y AoWdMbn coAMAONAfALTH of YLVAMA s.a ll?burph, Agep?r CMrbn Feb. 7LM0This 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 I)eparti-neat pf. Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 NOV-12-2008 10:06:17 -< Last Name First/Middle Begin Date Active Duty Status Service/Agency GLUNT BRADLEY 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. .. otJam- 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 i6 'the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty sts by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have e ence the person is on tractive-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. Lou obtain further information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you ern 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 onl,,. For historical information, please contact the Military Service S'CRA points-of-contact. 'T See: http /(www.defenselink.mil/faa/pis/PCO? SLDR.htmI 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. J2eport ID: FOUZLOMVOU f ?+ st tc :C/www.dmdc.osd.mil/scra/owa/scra.prc_Select 11/12/2008 C? r+? ?" ' C7 -n ? '? * 0 .? rv ?'? Sv ? c? ?; ?,a ? ?-? .. -?? ` q t3'1 ? ? ? ?= = '? ? -c ? T IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 08-5350-CIVIL TERM BRADLEY WENDEL GLUNT Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or ud ent was entered against you on 11 0 D (xx) Assumpsit Judgment in the amount of $1,964.33 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 ByATHONO*TORDE PR TY) BRADLEY WENDEL GLUNT 983 BIG SPRING RD SHIPPENSBURG, PA 17257 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1460 Koppers Building, 436 7`s Avenue, Pittsburgh, PA 15219 1888-434-0085