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Home My WebLink About08-6205IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK T Plaintiff No: - (0ot05 alvil er'IL. VS. JOSEPH W CRAMER COMPLAINT IN CIVIL ACTION 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 06943213 C A Pit ABR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No 0 Q'- 6 .L-C) S C)4:1 "1 z/^ JOSEPH W CRAMER 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: JOSEPH W CRAMER 1909 RITNER HWY CARLISLE, PA 17013 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXX8160 . 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 October 06, 2008 , in the amount of $15410.59 . 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 , JOSEPH W CRAMER INDIVIDUALLY , in the amount of $15410.59 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 WELTMAN EINBERG & REIS CO., L.P.A. 436 Se en h Avenue, Suite 1400 Pitts rg , PA 15219 (412) 434 7955 FAX: 412 338-7130 069 32 C A Pit ABR This law firm is a debt collector attetipf-ing to collect this debt for our client and any information obtained will be used for that purpose. CARD v`''°'.w tnter Amount Enclosed Below Payment Due Date 1 i -7-7 1 April 29, 2007 `' - Clete 30 SDSN6A01 0000356 JOSEPH CRAMER Will your payment get to us on time? Pay 1909 RITNER HWY your bill online and your payment can bs CARLISLE PA 17013-9310 made to your account on the some day. Visit Discovercard.com/payments today. 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. PO BOX 15251 Illrrrllrrnrllrllnrlrnll WILMINGTON DE 19886-5251 )...111 .d..1.111111))111)1)11111111111111111)I)II I1111d"I 000001986458376648198000000000000000296100 Discover Platinum Card Account Summary Closing Date; March 30, 2007 page 1 of 1 Account number ending in 8160 Previous Balance Payment Due Date April 29, 2007 Payments And Credits $15,410.59 Minimum Payment Due $2,961.00 Purchases - 15,410.59 Credit limit $12,900.00 Credit Available $0 00 Cash Advances + 0.00 + 0.00 . Cash Credit Limit $6,500.00 Balance Transfers Finance Char e + 0.00 Cash Credit Available $0,00 g s N New Balance + 000 $0.00 Cashback Bonus* Opening Cashback Bonus Balance $ New Cashback Bonus Earned 0.00 + 0,00 Dashback Bonus® Anrriversary -- -. _ - . _. _ Cashback Bonus Balance _ _ - - - - - - - Avadabls to Rexlsem _ $ 0.00 $ Date: April 18 _ .. _ _ _ - _ _ _ _ . .. - - - - -. 9.40_ ...- How Can We Help You? 1 • Visit Diacovsrcom to pay your bbl for no cost view It's your choice - 3 ways to hel , r latest Account information, earn and redeem rewards and more 2 Coll 1-SMDISCO p Please have your Discover Card available. . YER (347-2683) for fast, easy self-service options or to 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 $0 Fraud Liability Guarantee Use our Dis C d s. Post Trans' y cover ar with confidence. Da Payments and Credits Mar 31 Mar 31 INTERNAL CHARGE-OFF $ -15,410.59 EXHIBIT Finance Charge Summary Average Daily Daily Periodic Nominal ANNUAL PERCENTAGE ANNUAL PERCENTAGE Transaction Periodic F la es Rates RATES ACE MANCE current billing period: 13 days A GES QjAW&S Purchases $0 Cash Advances $0 0.07942% 0.07942% 28.99% F 28 99% F 28.99% $0 none . 28.99% The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above. $0 $O 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 # 6943213 JOSEPH W CRAMER 6011002261528160 ? ? 00 91 -- O C= ° SR a ^ Gil ?'..- v - ?F. .y T CZ) I at SHERIFF'S RETURN - REGULAR CASE NO: 2008-06205 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK CRAMER JOSEPH W VS ROBERT BITNER Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CRAMER JOSEPH W DEFENDANT the at 1724:00 HOURS, on the 21st day of October , 2008 at 1909 RITNER HWY CARLISLE. PA 17013 SHANNA GUTSHALL by handing to ADULT IN CHARGE 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 Iola'? /D8. 18.00 5.00 .00 10.00 00 33.00 Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 10/22/2008 WELTMAN WEINBERG REIS By: Depu her ff A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. JOSEPH W CRAMER Defendant No. 08-6205-CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT 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#6943213 Judgment Amount $ 16,910.59 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. Civil Action No. 08-6205-CIVIL TERM JOSEPH W CRAMER Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, JOSEPH W CRAMER above named, in the default of an Answer, in the amount of $16,910.59 computed as follows: Amount claimed in Complaint $15,410.59 Interest from date of judgment at the legal interest rate of 6.00% per annum Attorney's fees $1,500.00 TOTAL $16,910.59 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, quire PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 1400 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6943213 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A.,1400 Koppers Building, 436 7 h Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 1909 RITNER HWY, CARLISLE,PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff JOSEPH W CRAMER Defendant(s) IMPORTANT NOTICE TO: JOSEPH W CRAMER 1909 RITNER HWY CARLISLE,PA 17013 Date of Notice: WWR#: 06943213 Case # 6?-Ga"-=-?- , U . t W `c m 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 PATRICK THOMAS WOODMAN PA I.D. #34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 KOPPERS BLDG, 436 7TH AVE. PITTSBURGH, PA 15219 (412) 434-7955 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. JOSEPH W CRAMER Defendant Case no: 08-6205-CIVIL TERM NON-MILITARY AFFIDAVIT 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, JOSEPH W CRAMER 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, JOSEPH W CRAMER is not in the military service. Further Affiant sayeth naught. AFFIANT S RN TO AND SUBSCRIBED in my presence this day of --e-'M kW' - ZW23. `? L' COMMONWEALTH OF PENNSYLVANIA TARY PUBLI Notarial Seal Heidi J. Kelly, Notary Public City Of Plttsbt so. Alte"W County My Commisaft Evim Nov. 4.2009 Member, Pennsylvente Assooletlon of Noarles This 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 Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of I DEC-08-2008 10:29:03 < Last Name First/Middle Begin Date Active Duty Status Service/Agency CRAMER JOSEPH 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. 14. h1aut lot 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 to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can 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 only. For historical information, please contact the Military Service SCRA points-of-contact. See: http•//www defenselink mil/fact/pis/PC09SLDR html 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. Report ID: OSUWELZMHW https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 12/8/2008 t"D 49? ? t 0 1L7 r } IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 08-6205-CIVIL TERM JOSEPH W CRAMER Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Jud ent was entered against you on 09 (xx) Assumpsit Judgment in the amount of $16,910.59 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 By: ( - A(V?51?uo 4 PRO NOTAR EP Y) JOSEPH W CRAMER 1909 RITNER HWY CARLISLE, PA 17013 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 1400 Koppers Building, 436 7 h Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. JOSEPH W CRAMER Defendant No. 08-6205 CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA I . D #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#6943213 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 08-6205 CIVIL TERM JOSEPH W CRAMER Defendant PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. Sworn to and subscribed before me this _ nbuary 9 , N , RY P /V coMMO F Nab" seal JerMNbr M. BorwmW, Notary PubNe CV# of Pln.agh. A ftherry Cou* Ca1MV00on E*W Feb. 22.2D12 WELTMAN, WEINBERG & REIS CO., L.P.A. By: - James C. W brodt PA I . D #42 4 WELTMA INBERG & REIS CO., L.P.A. 1400 Kop ers Building 436 Sev nth venue Pittsbur h, A 15219 (412) 4 4- 955 WWR #6943213 f?•-- c::x 91 i r, °sn 'T G 1