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Home My WebLink About09-0063r 1. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: Qq- 00(03 CjVa~i~r-~M vs. COMPLAINT IN CIVIL ACTION JEFFREY A THOMAS 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 07129134 C A Pit ABR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No JEFFREY A THOMAS 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 b 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: JEFFREY A THOMAS 802 HIGHLAND CT MECHANICSBURG, PA 17050 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXX1713 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 $6575.26 . 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 JEFFREY A THOMAS ,INDIVIDUALLY in the amount of $6575.26 with interest at the legal rate of 6.000 per annum from date of judgment plus attorneys' fees of $1000.00 and costs. James WELTM 436 Pitt. (41 FAX 07 ~ ..__......_..,~.., s~.,~z WEINBERG & REIS CO., L.P.A. th Avenue, Suite 1400 gh, PA 15219 4-7955 2-338-7130 4 C A Pit ABR This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. iVIJ`.~~w.~ ~ PQ:iI~ Sbs7sss 56,57s.26 • CARD'' Payment Due Date DUE IMMEDIATELY 08 SDSN6A01 0006194 ~ `~~,~~, l~ JEFFREY THOMAS ~'" ~~ 802 HIGHLAND CT ~~ MECHANICSBURG PA 17050-1817 Enter Amount Enclosed Below ~ f-~t ~+/ Will your payment get to us on time2 Pay your bill online and your payment can be made to your account on the same day. Visit Diseover.com/payments today. PO BOX 6103 IIIr~~tl~~rlL~~Ir~Ir~rLll CAROL STREAM IL 60197-6103 Address, e-mail or telephone change$ Print change in space I~I~~~II~~~~~~I~'~I~~~~~~I~II~~~ above or go to Discovercard eom Print il dd ~~I~I~1111II~II~I~I'~~"f„II , . . your ema a ress to receive important Account information and special offers. 0000019864596382730070657526000000D0657526 - - ~ Discover More Card Account Summary .._ Closing Date: Ocbber 8, 2008 page 1 of 1 Account number ending in 1713 Previous Balance ' $6 575.26 Payment Due Date November 7, 2008 Payments And Credits , 000 Minimum Payment Due $6,575.26 Purchases + 0 00 Credit Limit $5,000.00 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 $6,575.26 Cashback Bonus® Opening Cashbaek Bonus Bolance $ Q,OQ New Cashback Bonus Eorned + p,00 Cashback Bonus Balance $ 0,00 Cashback Bonus® Anniversary Available Fo Redeem $ _ _ 0,00 ', Date: June 8 ;How Can We Hel You? 1 • Visit Diuover.cem fo pay your biN for no coat, view our p latest Account information, cam and redeem rewards and more It's your choice - 3 ways to help 2. Call 1-800-DISCOVER (347-2683) For fast, easy selFservice ~ Please have your Discover Card available. options or to speak with a Customer Service Account Manager i For TDD (assistance for hearing impaired) see reverse side 3' Write us at Discover Card, PO Box 30943, SaN Lake City, UT 84130 i ..Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence. ;Information For You While we are permitted under the Cardmember Agreement to increase the APRs on your Aceounf because your payment 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 Defauk Rate Plan section of the Cardmember Agreement for details. _.. - ,Finance Charge Summary ' Nominal Transaction Average Daily ANNUAL ANNUAL Periodic Fee ~ Daily Periodic PERCENTAGE PERCENTAGE F~~ pfNpC~~ al a Rates RATES RATES current billing period: 8 days ' Purchases $0 0.082169'0 29.99% F 29.99% $0 none . Cash Advances $0 0.08216% 29.999'0 F 29.99% $0 $0 previous billing period; 12 days Purchases $0 0.08216% 29.99% F 29.99% $0 none The rates that apply to your Account are either Fixed (F) or they may vary (VI as noted above. EXHIBI~f G.. , ~ 4 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 'e 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. (Signs. ) WWR# 7129134 Jeffrey A. Thomas '6011003815091713 ~.-~ r~ '`7 ~ 7 ,, t ~. ~-'~ .. +. ~ , °.i°j ~` _ Z ~ . Viz,. i ` ~( ~ J .~.. ~ CO { 0 ~ ~ a ~ r''4 „~ ~ J N /~