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Home My WebLink About08-7430I. % IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. SHELBY C REED Defendant No: od - cluiL 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 07076323 C A Pit ABR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No SHELBY C REED 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: SHELBY C REED 7 CORAL DR CARLISLE, PA 17013 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXX3813 . 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 December 02, 2008 , in the amount of $4233.77 . 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 $500.00 . 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 , SHELBY C REED INDIVIDUALLY , in the amount of $4233.77 with interest at the legal rate of 6.000% per annum from date of judgment plus attorneys' fees of $500.00 , and costs. ames 436 Pitt (412, 07 WEINBERG &I ' REIS CO., L.P.A. v nth Avenue, Suite 1400 gh, PA 15219 34-7955 2-338-7130 23 C A Pit ABR This law firm is a debt collector attting to collect this debt for our client and any information obtain' will be used for that purpose. .w JY,LJJ.I / CARD J4,Z33.// Payment Due Date DUE IMMEDIATELY 08 SDSN6A01 0015510 SHELBY REED 7 CORAL DR CARLISLE PA 17013-9401 Enclosed Below Will your payment get to us on time? Pay your bill ,line and your payment can be made to our account on the same day. Visit Dfscove com/payments today. PO BOX 1525 III. ,,II,,,fill, Address, e-mail or telephone change? Print change ins ace WILMINGTON E 19886-5251 above, or t Ac informs ion Youre-mail address to "'111' "'rlrlrr(rrl rrrlrlrrr?,I,I,I,,,,II?I?I??rrIII?I??I receive important Account count information and special offers. 00000198645878619587104233770000000042337 ExHiair Discover More Card Account S u mmary A Account number ending in 3813 Closing Date; September 8, 2008 page 1 of 1 Payment Due Date October 7, 2008 Minimum Payment Due $4 233 77 Previous Balance Payments And Credits $4,233.77 , . Credit Limit $3,300.00 Credit Available $0 00 Purchases Cash Advances - 0.00 + 0.00 . Cash Credit Limit $000 Balance Transfers + 0.00 Cash Credit Available $0 00 Finance Charges + 0.00 , New Balance + 000 _ $4,233.77 Casack Bonus® O Cashback Bonus la Nehback B onus Earned p; nce $ 0.00 X0.00 ;Cashback Bonus?Anniversary D t hk CaBonus a lance B _ Avto Redeem $ 0.00 a e: September 8 $ 0.00 How Can We Help You? I. Visit Discover.corn to a bill !It's your choice - 3 ways to help p y 2 Ccll 1 c n o ur for no cost, view your 2 Please have your Discover Card available . 8 00 DISCOVER (3 options or to speak with a ore 683) for fast easy self service . For TDD (assistance for hearing impaired) see reverse side 3. Write us at Discover Card ustomer Service Account Manager , PO Box 30943 Salt Lake City, UT 84130 , Transactions $0 Fraud Liability Guarantee U 'Information For You se your Discover Card w i confidence. While we are permitted under the Cardmember Agreement to increase the APRs on your Ac was late, we have chosen not to do so at thi ti ount because o s me. We have terminated, however, any intr purchases and any special balance transfer rate, and applied the standard APR for purcho purchases and balance tr f y ur payment uctory or promotional rate on t ans ers. However, we reserve the right to increase the APRs on yo minimum payment due by the payment due date. See the Default Rate Plan details ti o your outstanding balance of r Account if you fail to pay the . sec on of the C rdmember Agreement for Finance Charge Summary Average Dail Y Dail Periodic Nominal PERCE AGE ANNUAL B lances current billing period: 8 l Rates RATES PERCENTA RATES c ays Purchases $0 Cash Advances $0 0.0,4381% 15.99% F 15.99% Previous billing period: 27 days 0.06299% 22-99% F 22.99% Purchases $0 The rates that apply to your Acc t 0.0,4381% 15.99% F 15.99% oun are either fixed (F) or they may vary (V) as noted abov e. Transaction Periodic Fee C CHARGES $0 none $0 $0 $0 none 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 Accounts Manager of DFS Services LLC (Name) (Title) ,plaintiff herein, that (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# 7076323 Shelby C. Reed '6011002682893813 -74 CC7 "'< PC) SHERIFF'S RETURN - REGULAR CASE NO: 2008-07430 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS REED SHELBY C NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon REED SHELBY C the DEFENDANT , at 1950:00 HOURS, on the 5th day of January , 2009 at 7 CORAL DRIVE CARLISLE, PA 17013 by handing to SHELBY C REED 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 •????i?? ? ???,,,,?1 Affidavit .00 ? Surcharge 10.00 R. Thomas Kline .00 37.00 01/06/2008 WELTMAN WEINBERG REIS Sworn and Subscibed to By: °-?C-- before me this day Deputy Sheriff of A.D. N _. -° - n ; co l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. SHELBY C REED Defendant No. 2008-7430 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#7076323 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 2008-7430 SHELBY C REED 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.' PA 1. D. #4 1400 Kopl 436 SePittsbu(412)414 SWORN TO AND SUBSCRIBED before me this day of , 2009 NO Y OF nvaaA NOUNM Seal Anrdw M. Wmwdu. WMY Pubk 1WW CM* CNy at pxbi wgh, A#89 s C2 Ml Member. , Esquire s/Building venue A 15219 h7k?,w, ;? Cr:? . `f `? ? rte- s C.. ? G? '? ` r'rt -.,.