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Home My WebLink About09-0020 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: ~-OOo10 C1Vi~~Gr'1H vs. COMPLAINT IN CIVIL ACTION CARRIANNE WHITE Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. War'mbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 07131549 C A Pit ABR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No D~ ' u~:l CARRIANNE WHITE 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: CARRIANNE WHITE 585 BOXWOOD LN CARLISLE, PA 17015 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXX5604 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 17, 2008 in the amount of $8314.51 . 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 $1000.00 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 CARRIANNE WHITE ,INDIVIDUALLY in the amount of $8314.51 with interest at the legal rate of 6.OOOo per annum from date of judgment plus attorneys' fees of $1000.00 and costs. James C. a ro t,42524 WELTMAN, I ERG & REIS CO., L.P.A. 436 Sevent venue, Suite 1400 Pittsburgh PA 15219 (412) 434- 955 FAX: 412-3 8-7130 07131549 A Pit ABR 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. eia~,v~..°.:r w .titer 58,314.51 cnao 08 SJSNEA01 0006026 CARRIAiVNE WHITE 585 BOXWOOD LN CARLISLE PA 17015-4302 $8,314.51 Payment Due Date DUE IMMEDIATELY _-~ ~ ; ... r ~~:~3-~ ~'~{ ~; ., Enter Amount Enclosed Below r . £' Will your payment get to us on time$ Pay your bill online and your payment can be made to your account on the same day. Visit Discover.eom/payments today. PO BOX 6103 IIIniIIn~IluJnln~l,ll Address, e-mail or telephone change? Print change in space CAROL STREAM IL 60197-6103 above, or go to Dis:overcard.com. Print your email address fo ~'II"I~""'~~I~~~~~~~~~~~I~i~ii~l~l~~~~~~ll~l~~~~~~l~~~l~~l~ receive important Account information and special offers. 000001986458639146121083145100000000831451 Discover More Card Account Summary Closing Date: Account number ending in 5604 Payment Due Date November 7, 2008 Minimum Payment Due $8,314.51 Credit Limit $6,800.00 Credit Available $0,00 ' Cash Credit limit $0.00 Cash Credit Available $p,00 October 8, 2008 page 1 of 1 Previous Balance 58 314 51 Payments And Credits , . Purchases _ 0'00 Cash Advances + 0'00 Balance Transfers + 0.00 Financ a Char~ss + 0.00 _ New Balance + 000 _ $8,314.51 'Cashback Bonus® O i pen ng Cashback Bonus Balance $ 0 ~ New Cashback Bonus Earned =~ ;Cashback Bonus® Anniversary Ava fable to Redeem~ance $ 0.00 Date: February 8 - $ 0.00 . How Can We Help You? 1 • Visit Discowr.com to pay your bill for n r It s your choice - 3 ways to help o cost, view ur latest Account information, earn and redeem reward and more 2. Call 1.800-DISCOVER (347.2683) for F t ~ Please have your Discover Card available. For TDD (assistance for hearing impaired) see reverse side as , easy self-service options or to speak with a Customer Service Account Manager 3' Write us at Discover Card, PO Box 30943 'Transactions , SaM Lake City, UT 84130 $0 Fraud Liabflfty Guaran tee Use your Discover Card with confidence ,Information for You . While we are permitted under the Cardmember Agreement to increase the APRs on your Account because your payment i was late, we have chosen not to do so at this time. We have terminated, however, any introductory or promotional rate on purchases and any special balance transfer rate, and applied the standard APR For purchases to your outstanding balance of purchases and balance transfers. However, we reserve the right to increase the APRs on your Account iF you fail to pay the minimum payment due by the payment due date. See the Default Rate Plan section of the Cardmember Agreement for EXHI~I details. ,- __ _ . _. Finance Charge Summary Average Daily ANNUAL ANNUAL Transaction Daily Periodic P~EftTCESNiAGE RATES~AGE Periodic Fee Balances Rates __ CNANGES FINC~~ ~ current billing period: 30 days Purchases $0 0.079429'0 28.99% F Past Purchases $0 0.07942% 28.99°'o F 28.99% $0 none ;Cash Advances $0 0.079429'0 28.99% F 28.99q $0 none previous billing period: 6 days $0 $p Purchases $0 0.079429'0 28.999'0 F 28.999'0 The rates that a I to A $0 none pp y your ccount are either fixed (FI or they may vary (VI 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 she is Mag ig a Foight (Name) Accounts Manager of DFS Services LLC ,plaintiff herein, that (Title) (Company) she 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 her knowledge, information and belief. (Signa e) WWR# 7131549 Carrianne White '6011002500615604 '`fp ~ V'r" ~ ~ t" j ~J r.~ Lea t~-~ lq '0 p _ l (V ~ ~;_-' r ~- ,~ 1 '1 ~? -w W ~ C.C7 ~ 1 ~ "'t' ~~ '~' ~L. "S.