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Home My WebLink About08-6320IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION WORLD FINANCIAL NETWORK NATIONAL BANK Plaintiff No. b$ - (oSo10 e4_4 1tr*^- vs. KENNETH BROWN III Defendant COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, P.A.I.D.# 42524 Weltman,Weinberg & Reis Co.,L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412)434-7955 Fax: 412-338-7130 WWR#6799164 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION WORLD FINANCIAL NETWORK NATIONAL BANK Plaintiff vs. Civil Action No. 6 y, G 3 X6 c ly;1 4-ttp. KENNETH BROWN III 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 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 fizrther 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 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 in 220 W SCHROCK RD WESTERVILLE, OH 43081-0000. 2. Defendant is an adult individual residing at 4592 MANOR DR MECHANICSBURG,PA 17055. 3. Defendant applied for and received a credit card issued by World Financial Network National Bank bearing the account number 5942. 4. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of OCTOBER 16 2008, in the amount of $2,607.26. A true and correct copy of Plaintiffs 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 Cardholder Agreement between the parties provides that Plaintiff is entitled to the addition of finance charges at the rate of 0.00% per annum on the unpaid balance. 7. 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, KENNETH BROWN III individually, in the amount of $2,607.26 with continuing finance charges thereon at the rate of 0.00% per annum from OCTOBER 16 2008 plus 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. W brodt, Weltberg & Reis Co.,L.P.A. 436 Svenue, Suite 1400 Pitts15219 P.A.I/1)338-7'130 (412) Fax: 799164 ? 7?g Papa 1 of 1 This Month's Activity: y ew Thwooiptiftw LoowN4r1 AnaAtht ,' # : , Nor 4 0310200 00000000 001 LATE FEE $29.00 We an aNemp* q to work wkh you. M payment Is not reoefved your aooount will be turned over to our Reoovery Division. To malts a payment by phone using your bank aooount, or to discuss payment arrangallerds, please oall 1-800-695-9872. Stehow t Setrnmay: Aooount: 511166-M17-202111-51114 Payment Due Date: Today Crete Lnr1 Available Credit 00 $0.00 Aaarapepa?y B WNW* DAILY Psrkwb Rate $2A99A9 0.00040% Pwwlae lllid •e + Now Choose UA72.10 $20.00 03100/!000 : 0a rayandn0 ANNUAL TAGE RATE C 24 9900% - Pa + FWMNCE CHARGES ".00 03 5 ? fo Padod M? te Pty 00029 .so PER EN PERCENTAGE . Now - Balance ment um Pa Mini 6. 52,6 38 3 5991 00 Put Due MNinumFINANCE CNARGE 5820.09 $0.00 ANNUAL RATE 24.9900% y m . NOTICE.' 9" reverse a#db br InAsrnrsthn lave t«v at porloragon atrov Account Payment mud reach Number 6M _60 us by 2 pm ET on: Today Yss, I have mowed or updated E-11M.Reverse 3707- 02 Nsw Balance Minimum Payment .78 1.00 WE 4+ Please make checks poyable to: W"N6 -VALUE GrY FUR'N17URE Amount Enclosed KEMNETM E 62M III 4592 man OR Pltm•• r mum the poftn wNh your Wyk to: NECIMINICSOM PA 17055-4932 PO 80X 869704 SAN ANTONIO TX 78266-9704 07201004 00000067 58563707202654420002550760000631001 VERIFICATION The undersigned, does hereby verify subject to the penalties of 18 PA.C.S. 14904 relating to unworn falsifications to authorities, that he is Matthew Zak, Agency Auditor, of World Financial Network National Bank, plaintiff herein, that he is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his knowledge, information and belief. World Financial Miwork National Bank ? -W E 2 o ii l v - Fi 00 ? D ? w v cn ..s SHERIFF'S RETURN - REGULAR CASE NO: 2008-06320 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND WORLD FINANCIAL NETWORK NATION VS BROWN KENNETH III MICHELLE GUTSHALL Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BROWN KENNETH III the DEFENDANT , at 0014:50 HOURS, on the 29th day of October , 2008 at 4592 MANOR DRIVE MECHANICSBURG, PA 17055 KATHERINE LEWIS by handing to ADULT IN CHARGE together with a true and attested copy of COMPLAINT & NOTICE and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 14.00 .00 10.00 R. Thomas Kline 42.00 Sworn and Subscibed to before me this day 10/30/2008 WELTMAN WEINBERG & REIS By: De uty ff of A. D. t IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION WORLD FINANCIAL NETWORK NATIONAL BANK Plaintiff vs. No. 08-6320 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE KENNETH BROWN III Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, P.A.I.D.# 42524 Weltman,Weinberg & Reis Co.,L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412)434-7955 Fax: 412-338-7130 WWR#6799164 r ti IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION WORLD FINANCIAL NETWORK NATIONAL BANK Plaintiff vs. Civil Action No. 08-6320 CIVIL TERM KENNETH BROWN III 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: Attorney for 2718 Koppe 436 Seventl Pittsburgh, (412)434-) TO AND SUBSCRIBED before me this / 7 day of L)Mtem ltxj?, 2008 N TARY PUBLIC jilding ?nue 5219 ?ublrc ?!_ r;nst.fr "f CitWa`s?' ucyh,, r}iuly c0200 c 0 (Mr? ;?,ation of Notaries MY M01f?be?, Per neyty :r;., , , , , C_` r.,,a ;) rte.. ' 7 _. , ?;,} k ., ?:.'