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Home My WebLink About08-7432 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. PAMELA A DUNKLEBERGER Defendant No: OS ^ 7q v OLv Il CCOMPLAINT 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 07076390 C A Pit ABR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. PAMELA A DUNKLEBERGER Defendant Civil Action No 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: PAMELA A DUNKLEBERGER 103 PETERSBURG RD CARLISLE, PA 17013 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXX2074 . 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 November 26, 2008 , in the amount of $4408.50 . 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 , PAMELA A DUNKLEBERGER INDIVIDUALLY , in the amount of $4408.50 with interest at the legal rate of 6.000% per annum from date of judgment plus attorneys, fees of $500.00 , and costs. James c. WELTMAN, 436 Seve Pittsbur (412) 43 FAX: 41 0707639 This law firm is a debt collector attempt our client and any information obtained w ro t,42524 INBERG & REIS CO., L.P.A. Avenue, Suite 1400 PA 15219 55 -7130 Pit ABR to collect this debt for be used for that purpose. v War V L; M $4,408.50 + CARD 22 SDSN6A01 0015721 PAMELA DUNKLEBERGER 103 PETERSBURG RD CARLISLE PA 17013-3131 .. .., ..._... _.._ ,.Z..... ,vuniuer vuurrig in LVI4 $4,408.50 I Enter Amount Enclosed Below EXHIBIT Payment Due Date $ 70 '74 3 9Q October 21, 2008 Please make check payable to Discover Card. Minimum pa?yyment due includes a past due amount of $766.00. Will your payment get to us on time? Pay your bill online and your payment can be made to your account on the same day. Visit Discover.com/payments today. PO BOX 15251 111.111111111 IN WILMINGTON DE 19886-5251 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. 000001986458014733675044085000000000440850 Discover More Card Account Summary Closing Date: September 22, 2008 page 1 of 1 Account number ending in 2074 Previous Balance $4,408.50 Payment Due Date October 21, 2008 Payments And Credits 0.00 'Minimum Payment Due $4,408.50 Purchases + 0.00 Credit Limit $3,300.00 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 . $4,408.50 'Cashback Bonus® Opening Cashback Bonus Balance $ 0.00 New Cashback Bonus Earned + 0.00 Cashback Bonus Balance $ 0,00 Cashback Bonus® Anniversary- Available to Redeem .. $ , . .. _ 0100 Date: July 22 How Can We Hel You? I . Visit Discover.com to pay your bRi for no cost, view our p latest Account information, earn and redeem rewards and more It's your choice - 3 ways to help 2. Call 1-800-DISCOVER (347-2683) for Fast, easy self service Please have your Discover Card available. 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, Salt Lake City, UT 84130 Finance Charge Summary Average Daily Nominal ANNUAL ANNUAL Periodic Transaction Fee Daily i Balances Periodic Rates PERCENTAGE RATES PERCENTAGE RATES FINANCE CHARGES FINANCE CHARGES current billing period: 22 days Purchases $0 0.07942% 28.99% F 28.99% $0 none Cash Advances $0 0.07942% 28.99% F 28.99% $0 $0 previous billing period: I 1 days Purchases $0 0.07942% 28.99% F 28.99% $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. ignature) WWR# 7076390 Pamela A. Dunkleberger '6011002940672074 vi W 0 r cv r-a c? C:7 N ?y C, J "T7 ':=P C z 9"x'1 --C 6 SHERIFF'S RETURN - REGULAR CASE NO: 2008-07432 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS DUNKLEBERGER PAMELA A TIMOTHY BLACK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPT,ATNT C- rTn'rTr- was served upon DUNKLEBERGER PAMELA A DEFENDANT the , at 1450:00 HOURS, on the 29th day of December , 2008 at 103 PFTTRR.qPTTRr- pnrn CARLISLE, PA 17013 by handing to PAMELA A DUNKLEBERGER 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 18.00 Service 4.50 Affidavit .00 .??.?.err?+ct.C ??a?%''.,.?,,P Surcharge 10.00 R. Thomas Kline .00 32.50 12/30/2008 WELTMAN WEINBERG REIS Sworn and Subscibed to By. -X/- before me this day eputy Sheriff of A.D. 46 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff Vs. PAMELA A DUNKLEBERGER Defendant No. 08-7432-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 1.5219 (412) 434-7955 WWR#7076390 Judgment Amount $ 4,908.50 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. PAMELA A DUNKLEBERGER Defendant TO THE PROTHONOTARY: Civil Action No. 08-7432-CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, PAMELA A DUNKLEBERGER above named, in the default of an Answer, in the amount of $4,908.50 computed as follows: Amount claimed in Complaint $4,408.50 Interest from date of judgment at the legal interest rate of 6.00% per annum Attorney's fees $500.00 TOTAL $4,908.50 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, 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#7076390 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A.,1400 Koppers Building, 436 7t' Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 103 PETERSBURG RD, CAR.LISLE,PA 17013 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA L CIVIL DIVISION DISCOVER BANK Plaintiff Vs. PAMELA A DUNKLEBERGER Defendant Case No. 08-7432 CIVIL TERM IMPORTANT NOTICE TO: PAMELA A DUNKLEBERGER 103 PETERSBURG RD CARLISLE, PA 17013 t? Date of Notice: V 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 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA. 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A. By: ?t a-W A-- WOd Patrick Woodman P.A.I.D.# 34507 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 7076390 A PIT J4C IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. PAMELA A DUNKLEBERGER Case no: 08-7432-CIVIL TERM NON-MILITARY AFFIDAVIT Defendant 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, PAMELA A DUNKLEBERGER 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, PAMELA A DUNKLEBERGER is not in the military service. Further Affiant sayeth naught. , 7 A A ?? ?e _? AFFIANT SWORN TO AN UBSCRIBED in my presence this day y 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. of Fe COMMONWEALTH OF PENNSYLVANIA Notarial Seal Wendy L. Gault Notary Public NOTAR PUBLIC City of P'RtsburcJh, AlleghenCOur4y My Commission Expires July member, Pennsylvania Association of Notaries Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 FEB-09-2009 10:25:19 < Last Name First/Middle Begin Date Active Duty Status Service/Agency DUNKLEBERGER PAMELA 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. &MY, In. 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/faq/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: BXZMVGPXIA https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 2/9/2009 W C:., IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 08-7432-CIVIL TERM PAMELA A DUNKLEBERGER 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 (xx) Assumpsit Judgment in the amount of $4,908.50 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: P ON PUTY) PAMELA A DUNKLEBERGER 103 PETERSBURG RD 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. PAMELA A DUNKLEBERGER Defendant(s) No. 08-7432 CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT 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) 434-7999 WWR#7076390 DIS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. PAMELA A DUNKLEBERGER Defendant(s) Civil Action No. 08-7432 CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WELTMAN, WEINBERG & REIS CO., L.P.A. Sworn to and subscribed before me this l day of August, 09 NO ARY PUBJ C Esquire & REIS CO., L.P.A. (412) 4 By: Avenue PittsbuA 15219 436 SeF4-7999 James C. W PA I.D. # 4: WELTMAI` 1400 Kop WWR #7076390 Naftrwi C ?ni A JorNNpwft CNWIeW I.VAf MA y commPr?ipn'"pi'. AlMgheny County rune ? X10 ber, enrn 2004 AUG 24 PH 12.08 eTN' cuV $8 . oo pt, ft r" r" co 4Qgwgq ?'? aa9?yg