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Home My WebLink About08-6818n IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: O8- tog 18 C?vi?T?l-h? VS. COMPLAINT IN CIVIL ACTION SAMER F THABATEH 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 06982297 C A Pit ABR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No SAMER F THABATEH 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: SAMER F THABATEH 320 CONTEMDRA DR MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXX7930 . 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 23, 2008 , in the amount of $15645.15 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 , SAMER F THABATEH INDIVIDUALLY , in the amount of $15645.15 with interest at the legal rate of 6.000% per annum from date of judgment plus attorneys' fees of $1500.00 , and costs. WELTMAN REIS CO., L.P.A. James 7Pit 42524 436 Se n Suite 1400 Pittsb rg 19 (412) 43 -FAX: 1 30698 29 C R This law firm is a debt collector attemng to coll ect this debt for our client and any information obtained ill be used for that purpose. r,?. ;`)V tK so .oo ".'"""" "' "Y1O°"' vue ^ccaum FNumoer enamg in /yJu VIJt.,< $3,067.00 i CARD Enter Amount Enclosed Below Payment Due Date $ j July 29, 2008 30 SDSN6A01 0004452 SAMER THABATEH Will your payment get to us on time? Pay 320 CONTEMDRA DR ` your bill online and your payment can be MECHANICSBURG PA 17055-7513 made to your account on the same day. Visit Discover.com/payments today. PO BOX 15251 111111111 gill 1111111111 Address, e-mail or telephone change? Print change in space WILMINGTON DE 19886-5251 above, or go to Discovercard.com. Print your e-mail address to )'1)"hill is Iill IIll )III)l11)r11111ill11111rr1))1)111 receive important Account information and special offers. 000001986458174667671000000000000000306700 Discover More Card Account Summary Closing Date; Account number ending in 7930 Payment Due Date July 29, 2008 Minimum Payment Due $3,067.00 Credit Limit $12,750.00 Credit Available $0.00 Cash Credit limit $6,600.00 Cash Credit Available $0,00 June 30, 2008 page 1 of 1 Previous Balance $15 645 15 Payments And Credits , . Purchases 15,645.15 Cash Advances + 0.00 Balance Transfers + 0.00 Finance Charges + 0.00 New balance + 0.00 _ $0.00 'Cashback Bonus® O i pen ng Cashback Bonus Balance $ 000 New Cashback Bonus Earned Cashback-Bonus® Anniversary - Bonus Balance $ 0.00 Ava table Date: August 16 . $ . _ 0.00.- How Can We Help You? 1 • Visit Di scover.com to pay your b1l for no t i t's your choice - 3 ways to help v ew , our l atest A information, earn and re cos ccount deem rewards and more 2. Call 1-800-DISCOVER (347--2683) for fa t l Please have your Discover Card available. s , easy se f service options or to speak with a Customer Service Account Ma For TDD (assistance for hearing impaired) see reverse side nager 3' Write us at Discover Card, PO Box 30943 , Sah Lake City, UT 84130 Transactions $0 Fraud Liability Guarantee U Trans. Post se your Discover Card with confidence. Dale Date Payments and Credits Jun 30 Jun 30 INTERNAL CHARGE-OFF EXHIBIT $-15,645.15 'Finance Charge Summary Avers a Daily g Pe ilodic Balanc s R Nominal Transaction P RCENTAGE PERCE AGE Periodic fee A e ates current billing period: 14 days GE F CINARICE RATES RATES C -?? Purchases $0 0.07942% Past Purchases $0 0.07942% 'Cash Advanc 28.99% F 28.99% F 28.99% $0 none $0 es $0 0.07942% The rates that aPPIY to your Account are either Fixed (F or the none 28.99% F 28.99% 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 # 6982297 SAMER F THABATEH 6011002033277930 D ? n Uwi tW)1 .? ?.. 4- i ?v c= 0 C:o co co R nz 0 SHERIFF'S RETURN - REGULAR CASE NO: 2008-06818 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS THABATEH SAMER F TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon THABATEH SAMER F the DEFENDANT at 0020:12 HOURS, on the 19th day of November , 2008 at 320 CONTEMPRA DRIVE MECHANICSBURG, PA 17055 EYMAN OPAID 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: So Answers: Docketing Service 18.00 9.00 Affidavit 00 Surcharge 10.00 R. Thomas Kline .00 37.00 11/20/2008 WELTMAN WEINBERG & REIS Sworn and Subscibed to By: before me this day 'Clo epu y Sheri f of A.D. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. SAMER F THABATEH Defendant No. 08-6818 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END WITH PREJUDICE 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#6982297 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 08-6818 CIVIL TERM SAMER F THABATEH Defendant PRAECIPE TO SETTLE AND DISCONTINUE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR: Please kindly Settle and Discontinue the above-captioned matter upon the records of the Court and mark the cost paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James ?WtT rodt, Esquire PA 1. D. 24 1400 Kop rs B iiding 436 Seve th enue Pittsbur , P 15219 (412) 4 4-7 55 SWORN TO AND SUBSCRIBED COMMONWEALTH OL PENNSYLVANIA Of PmsburCounty NoMAssoclation City Heidi J. Kblic MY Commission 4, 2009 Member, Pennsylvanla of Notaries before me this 69-el day N - CT." Z ^ C2, CJ