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Home My WebLink About09-0681 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. CHERYL I CULLEN Defendant No : Cq - (981 COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF THIS PARTY: OF James C. Warmbro WELTMAN, WEINBER 436 Seventh Aven Pittsburgh, PA (412) 434-7955 FAX: 412-338-713 07184623 C A Pit t, 42524 & REIS CO., L.P.A. e, Suite 1400 5219 ABR IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No CHERYL I CULLEN Defendant COMPLAINT AND NOTICE TO DEF You have been sued in court. If you wish to claims set forth in the following pages, you must twenty (20) days after this complaint and notice a written appearance personally or by an attorney with the court your defenses or objections to the against you. You are warned that if you fail to proceed without you and a judgment may be entered court without further notice for any money claime for any other claim or relief requested by the pl money or property or other rights important to yo PENNSYLVANIA defend against the take action within re served, by entering and filing in writing claims set forth o so the case may against you by the in the complaint or intiff. You may lose YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELE HONE THE OFFICE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL H LP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES T T MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR O FEE. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATIi 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 COMPLAINT 1. Plaintiff, is a corporation with offices at 6 00 New Albany Rd, New Albany, OH 43054. 2. Defendant is adult individual(s) residing at below: CHERYL I CULLEN 739 ERFORD RD CAMP HILL, PA 17011 address listed 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number XXXXXXXXXXXX5957 . 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 cur due and owing to Plaintiff, as of January 21, 2009 $6897.08 . 5. Defendant is in default by failing to make pay rently has a balance in the amount of is when due. 6. Plaintiff avers that the Agreement between the parties provides that Defendant will pay Plaintiff's attorneys' fee . 7. Plaintiff avers that such attorneys' fees willlamount to $1000.00 i 8. Although repeatedly requested to do so by Pla?ntiff, Defendant has willfully failed and/or refused to pay the balanc? due to Plaintiff. Wherefore, the Plaintiff prays for Judgment 'n its favor and against Defendant , CHERYL I CULLEN INDIVIDUALLY , in the amount of $6897.08 with interest at the legal rate of 6.000° per annum from date of judgment plus attorneys' fees of $1000.00 , an costs. This law firm is a debt collector a our client and any information obta Jame C. Wa ro t,42524 WEL WEI ERG & REIS CO., L.P.A. 436 S venth Avenue, Suite 1400 Pi is urgh, P 15219 ( 2) 434-795 F 412-338--)130 7 4623 C A Pit ABR mpting to collect this debt for ned will be used for that purpose. -- - • -?.+..? r ?yrivor or1u 111 Iil .1I7of VO ` ;,,,,+?V tK $6,897.08 $6,897.08 Enter Amount Enclosed BelowllI CARD Payment Due Date $ December 14, 2008 Please make check payable to Di cover Card. Minimumpayymment due includes a past due ,399.00. 15 SDSN6A01 0002763 amount ofp$ T ' CHERYL CULLEN Will your payment get to us on time? Pay 739 ERFORD RD your bill online and your payment an be CAMP HILL PA 17 011-1126 made to your account on the same day. Visit Discover.com/payments toda . t 1 PO BOX 6103 Illur?lunnllr? Inln?l ~ CAROL STREAM IL 60197-6103 Address, e-mail or telephone change? Print change in space 'rllrrllrrri?rlllrl'rlrrrlrllf"r'1111111I?'ll""tIl"I'tll above, or go to Discover.com. Print your e-mail address to receive important Account information and special offers. 000001986458793814746068970800000000689708 Discover More Card Account Summary Closing Date: November 15, 2008 Account number ending in 5957 Previous Balance Payment Due Date December 14, 2008 Payments And Credits Minimum Payment Due $6,897.08 Purchases Credit Limit $5,500.00 Cash Advances Credit Available $0.00 Balance Transfers Cash Credit Limit $0.00 finance Charges Cash Credit Available $0.00 New Balance I of I 897.08 0.00 0.00 0.00 0.00 0.00 (;ashback Bonus* Opening Cashback Bonus Balance $ 0.00 New Cashback Bonus Earned + 200 Cashback Bonus Balance CCashback-Bonu-A Anniversary - - - - AvallableJo-Redeem $ 0.00 Date: January 15 How Can We Help You? 1. V latest Account isit Discovercom to pay your bill for no cost, view information, It's your choice - 3 ways to help 2. Call 1-800-DISCOVER (347--2683) fo efast, easy sel Please have your Discover Card available. options or to speak with a Customer Service Accour 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 Dail Nominal Daily ANNUAL ANNUAL Periodic Y Periodic PERCENTAGE PERCENTAGE FINANCE Balances Rates RATES RATES CHARGES current billing period: 15 days Purchases $0 Cash Advances $0 Previous billing period: 14 days i Purchases $0 The rates that apply to your Accour 0.07942% 28.99% F 28.99% $0 0.07942% 28.99% F 28.99% $0 0.07942% 28.99% F 28.99% $0 it are either fixed (F) or they may vary (V) as noted above. $0 and more i Manager EXHIBIT -. ?-®® L The undersigned does heret unswom falsifications to authorities Accounts Manager of (Title) he is duly authorized to make this V in Civil Action are true and correct t WWR# 7184623 Cheryl I. Cullen '6011002690725957 K? tMCa i ?J - Jc cfp SHERIFF'S RETURN - REGULAR CASE NO: 2009-00681 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS CULLEN CHERYL I KENNETH E GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CULLEN CHERYL I the DEFENDANT , at 0019:52 HOURS, on the 12th day of February-, 2009 at 739 ERFORD RD CAMP HILL, PA 17011 e"TTTT)VT ! TTT T T?TT by handing to DEFENDANT 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 11 Service 13.50 j;;,4w.,e - I Affidavit .00 -4.00 ?O? Surcharge 10.00 R. Thomas Kline .00 41.50 02/13/2009 WELTMAN WEINBERG & REIS Sworn and Subscibed to By: before me this day Dep ty She if of A. D. `_ .s ? 1?Ci _ ^^? _ ?..e..4 ?.-+ ... {?u? IN TH1? COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BAi K Plaintiff No. 09-681 CIVIL TERM ?s PRAECIPE TO SETTLE, DISCONTINUE AND END WITH PREJUDICE TO REFILE CHERYL I CULLEN Defendant(s) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire PA I.D. #42524 i WELTMAN, WEINBERG & REIS CO., L.P.A 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#7184623 s .* IN TAE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER Plaintiff Civil Action No. 09-681 CIVIL TERM CHERYLI S) TO THE PROTHONOTARY OF COUNTY: Settle, Discontinue and End With Prejudice to Refile the above-captioned matter upon the records of the Court and mark th4 costs paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By. ---- JamesC. rmbrodt, Esquire PA I.D. # 24 WELTM , WEINBERG & REIS CO., L.P.A 1400 K p rs Building 436 S e th Avenue Pitts r , PA 15219 (41 34-7955 W #7184623 COMMONWEALTH OF PENNSYLVANIA Notarial Sail - I Wayne A. Jones, Notary Public i City o' ;;I+ttsburgh, Allegheny County I w commission June 29,1010 Member, Pennsykwge Aswolatlon o/ Notaries fit +" r n 2009 HA I z "' 20 Ph 12: G'w f Ty