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Home My WebLink About08-5360t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. ALEXIS LASKOWSKI Defendant No : 02 X3(00 0,1vi k le.m 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 06921613 C A Pit ABR c IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No ALEXIS LASKOWSKI 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 page-, 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 t 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: ALEXIS LASKOWSKI 307 GLENN AVE BOILING SPRGS, PA 17007 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXX3297 . 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 $2183.21 . 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 B. 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 , ALEXIS LASKOWSKI INDIVIDUALLY , in the amount of $2183.21 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. hrmbrodt,42524 WELTMAN, INBERG & REIS CO., L.P.A. 436 Sev n Avenue, Suite 1400 Pitts rg PA 15219 (412) 43 -7955 FAX: 41 338-7130 0692 6 C A Pit ABR This law firm is a debt collector attem ing to collect this debt for our client and any information obtained will be used for that purpose. UIb(. V tIK $2,183.21 $2,183.21 Enter Amount Enclosed Below CARD Payment Due Date $ 0 July 21, 2008 Please make check payable to Discover Card. Minimum payment due includes a past due amount of 11353.00. 22 SDSN6A01 0004811 - ALEXIS LASKOWSKI _ Will your payment get to us on time? Pay 307 GLENN AVE - your bill online and your payment can be made to your account on the same d?y. Visit BOILING SPRGS PA 17007-9774 Dfscovercard.com/paymentstoday. ..1.1"1'1'11rs1 PO BOX 15251 11111111It WILMINGTON DE 19886-5251 Address, e-mail or telephone change? Print change in above, or go to Discovereard.com. Print your e-mail add ess to receive important Account information and special offers. 000001986458024548931021832100000000218321 Discover More Card Account Summary Closing Date: June 22, 2008 page 1 of 1 Account number ending in 3297 Previous Balance $2,183.21 Payment Due Date July 21, 2008 Payments And Credits 0.00 Minimum Payment Due $2,183.21 Purchases + 0.00 Credit Limit $2,000.00 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 $2,183.21 Cashback Bonus® Cashback Bonus® Anniversary Date: April 22 Opening Cashback Bonus Balance New Cashbock Bonus Earned Cashback Bonus Balance Available to Redeem $ 0.00 + 0.00 $ 00.00 .00 How Can We Help You? 1. Visit Discover com to pay yew 6M for no cost, view ur latest Account information, earn and redeem rewardaoand more It's your choice - 3 Ways to help 2. Call 1-800-DISCOVER (347.2683) For fast, easy self service options or to speak with a Customer Service Account Manager Please have your Discover Card available. 3. Write us at Discover Card, PO Box 30943, For TDD (assistance for hearing impaired) see reverse side Salt Lake City, UT 84130 EXHIBfT Finance Charge Summary Nominal Transaction Averoge Daily ANNUAL ANNUAL Periodic Fee Daily Periodic PERCENTAGE PERCENTAGE FINANCE FINANCE Balances Rates RATES RATES CHARGES CHARGES current billing period: 22 days Purchases $0 0.05477% 19.99% F 19.99% $0 none Cash Advances $0 0.06299% 22.99% F 22.99% $0 s0 previous billing period: 4 days Purchases $0 0.05477% 19.99% F 19.99% $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 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 # 6921613 ALEXIS LASKOWSKI 6011002950223297 S, SHERIFF'S RETURN - REGULAR CASE NO: 2008-05360 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS LASKOWSKI ALEXIS STEVE BENDER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LASKOWSKI ALEXIS the DEFENDANT , at 0013:40 HOURS, on the 25th day of September, 2008 at 307 GLENN AVENUE BOILING SPRINGS, PA 17007 HEATHER LASKOWSKI by handing to WIFE OF DEFENDANT 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 ID/V401, So Answers: 18.00 5.00 %j .00 10.00 R. Thomas Kline .00 3 09/26/2008 WELETMAN WEINBERG & REIS Sworn and Subscibed to before me this By: day Deputy Sheriff of A. D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. ALEXIS LASKOWSKI Defendant No. 08-5360-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#6921613 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 08-5360-CIVIL TERM ALEXIS LASKOWSKI 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: James C. a #4 52 PA 1. D. 1400 Ko ers 436 Sev, nth Pittsbu h, P (412) 34-7 55 WW 1613 SWORN TO AND SUBSCRIBED before me this day of No." 2008 NO RY P IC WANIA M",CoMm tw of PENN3YCounty del Seal orOweki, W WY PIJW 0, a M ? 2 - a rodt, Esquire uilding enue 15219 C r CD M H C? ^C