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Home My WebLink About04-1934Our File No. 183277 ATTORNEYS FOR PLAINTIFF ERIC M. BERMAN, P.C. BY: Eric M. Berman, Esquire, I.D. 83698 BY: Robert M. Kline, Esquire,I.D. 56479 198 Allendale Road, Suite 306 King of Prussia, PA 19406 (610) 265-7720 ------------------------------------------X DISCOVER BANK c/o ERIC M. BERMAN, P.C. 198 Allendale Road, Suite 306 King of Prussia, PA 19406 Vs. ARTHUR A THOMAS 5141 S DEERFIELD AVE MECHANICSBURG, PA 17050 2496 -----------------------------------------X COURT OF COMMON PLEAS COUNTY OF CUMBERLAND TRIAL DIVISION CIVIL ACTION Term N0.0'4 -14.3 y (210cCEE A-t7ll 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 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 this complaint or for any other claim or relief required 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. 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. LAWYER REFERENCE SERVICE COUNTY OF CUMBERLAND BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PA 17013 800-990-9108 Our File No. 183277 ATTORNEYS FOR PLAINTIFF ERIC M. BERMAN, P.C. BY: Eric M. Berman, Esquire, I.D. 83698 BY: Robert M. Kline, Esquire,I.D. 56479 198 Allendale Road, Suite 306 King of Prussia, PA 19406 (610) 265-7720 -----------------------------------------X DISCOVER BANK c/o ERIC M. BERMAN, P.C. 198 Allendale Road, Suite 306 King of Prussia, PA 19406 VS. ARTHUR A THOMAS 5141 S DEERFIELD AVE MECHANICSBURG, PA 17050 2496 -----------------------------------------X COMPLAINT COURT OF COMMON PLEAS COUNTY OF CUMBERLAND CIVIL ACTION Term No. O14_ /g'3y CIUC.I. 7Ev,,*3 1. Plaintiff, DISCOVER BANK is a DELAWARE STATE BANK authorized to do business in the Commonwealth of Pennsylvania with its place of business at 3311 MILL MEADOW DRIVE, HILLIARD, OH 43026. 2. The Defendant(s), ARTHUR A THOMAS , resides at 5141 S DEERFIELD AVE , MECHANICSBURG, PA 17050-2496. 3. There is due from the Defendant(s) the sum of $2,282.65 for credit extended by Plaintiff to Defendant(s), acct. no. 6011002440322485, and which such credit was drawn and used by the Defendant(s). Defendant(s) is in default for failure to make payments for such use. 4. The Plaintiff has made demand upon the Defendant(s) for payment of monies in the sum of $2,282.65 advanced to Defendant(s) through Defendant(s) use of the above-referenced credit account, but Defendant(s) has failed and refused to pay the said sum or any part thereof. 5. All applicable credits, if any, have been duly applied to Defendant(s) credit account. WHEREFORE, Plaintiff claims of the Defendant(s) the sum of $2,282.65 plus interest, attorneys fees and costs which are justly due and owing from the Defendant(s) to the Plaintiff. ERIC M. BE1?AN, P.C. Dated : APRIL 23, 2004 `/ 1 BY : In/?? ERIC M. BERMAN, ESQUIRE BY: ROBERT M. KLINE ESQUIRE SPACEBNW-ZN Attorneys for Plaintiff VERIFICATION Eric M. Berman, Esquire, being duly sworn according to law, deposes and says that he is the Principal attorney of Eric M. Berman, P.C., attorneys for the Plaintiff, and/or Robert M. Kline, Esquire, being duly sworn according to law, deposes and says that he is an associate attorney with said firm, and as said attorney, is authorized to take this verification on its behalf, and that the facts in the Complaint as set forth therein are true and correct to the best of his knowledge, information and belief. I verify that the statements made in the within instrument are true and correct. I understand that false statements are subject to the penalties of 18 Pa C.S.A. Section 4904 relating to unsworn falsifications to authorities. ERIC M. BERMAN, ESQUIRE Dated: APRIL 23, 2004 ROBERT M. KLINE, ESQUIRE SPACEBNW-ZN d C t' e - o r ° -n z, m v•a. C.: nd .. `lt r Jm rl) cin SHERIFF'S RETURN - REGULAR CASE NO: 2004-01934 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS THOMAS ARTHUR A VALERIE WEARY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon THOMAS ARTHUR A the DEFENDANT , at 2112:00 HOURS, on the 20th day of May , 2004 at 5141 S DEERFIELD AVE MECHANICSBURG, PA 17050 by handing to CARLA THOMAS, SISTER, ADULT IN CHARGE 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: Docketing Service Affidavit Surcharge So Answers: 18.00 7.59 tats .00 10.00 R. Thomas Kline .00 35.59 05/21/2004 ERIC BERMAN Sworn and Subscribed to before By me this a y? day of o2bY7 ?/ A. D. rothonotary ' I7epu" tye ?Yier?'ff Our File No. 51004125 ATTORNEY FOR DEFENDANT Edward A. Thomas, Esquire, I.D. 54869 P.O. Box 7277 Mechanicsburg, PA 1050 (443) 744-9809 --------------------------------X COURT OF COMMON PLEAS COUNTY OF CUMBERLAND DISCOVER BANK c/o ERIC M. BERMAN, P.C. 198 Allendale Road, Suite 306 King of Prussia, PA 19406 VS. ARTHUR A. THOMAS 5141 S. Deerfield AVE. MECHANICSBURG, PA 17050 ---------------------------------X CIVIL ACTION TERM NO. 04-1934 Civil Term Answer Admitting Averment in Part and Denying in Part Due to Lack of Knowledge or Information Admitted in part, denied in part. :It is admitted only that Plaintiff extended credit to Defendant acct. no. 6011002440322485 and Defendant did use such credit. All of the remaining aspects of this averment are denied, as after reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to their truth. WHEREFORE, Defendant is rejecting Plaintiff's claim for the sum of $2,282.65 plus interest, attorneys fees and costs, on the grounds that they are not justly due and owing by Defendant to Plaintiff,. Dated: May 24, 2004 Arthur homas By: Edward A. Thomas, Esquire Attorney for Defendant N {' cf?2 rla a -40 Ln ` .c- Curtis R. Long Prothonotary Offire of the Protbonotarp Cumberlanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor ?)41 - / Q 3 q CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 5TH DAY OF NOVEMBER 2007 AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R C P 230.2. BY THE COURT, CURTIS R. LONG PROTHONOTARY One Courthouse Square • Carlisle, Pennsylvania 17013 • (717) 240-6195 • Fax (717) 240-6573