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Home My WebLink About04-2267IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. GEOFFREY S.DUNKLE Defendant No. 041- a?C7 '7v7 l COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Sofia Kokkini, Esquire PA I.D. #91535 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03462547 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. GEOFFREY S. DUNKLE Defendant COMPLAINT IN CIVIL ACTION 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 3311 Mill Meadow Drive, Hilliard, OH 43026. 2. Defendant is an adult individual residing at 981 Hummel Avenue, Lemoyne, PA 17043. 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011002140637315. 4. Defendant made use of said credit card and has currently a balance due and owing to Plaintiff, as of April 29, 2004, in the amount of $6,449.93. 5. Defendant is in default of the terms of the cardholder Agreement having not made monthly payments to Plaintiff thereby rendering the entire balance immediately due and payable. 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 $900.00. 8. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the principal balance, finance charges or any part thereof to Plaintiff. WHEREFORE, Plaintiff demands Judgment in its favor and against Defendant, Geoffrey S. Dunkle, in the amount of $6,449.93 with interest at the legal interest rate of 6% per annum from date of judgment plus attorneys' fees of $900.00, and costs. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED SHALL BE USED FOR THAT PURPOSE. WELTMAN, WEINBERG & REIS, CO., L.P.A. cJ? Sofia Li i, Es uire 9 PA I.D. #91535 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W WR#:03462547 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsifications to authorities, that he/she is Rnhpr4 Adk i n (Name) Accounts Manager of Discover Financial Services Inc., servicing agent of the plaintiff herein, that (Title) (Company) he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Complaint are true and correct to the best of his/her knowledge, information and belief. (Signature) W WR# ?'? QO ? G2 ?; ? ? SHERIFF'S RETURN - REGULAR CASE NO: 2004-02267 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS DUNKLE GEOFFREY S 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 DUNKLE GEOFFREY S the DEFENDANT , at 1914:00 HOURS, on the 20th day of May 2004 at 981 HUMMEL AVENUE LEMOYNE, PA 17043 by handing to GREGORY S DUNKLE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 11.04 Affidavit .00 Surcharge 10.00 .00 39.04 Sworn and Subscribed to before me this .q t! day of o2(h7? A.D. / ?Prothonotary So Answers: R. Thomas Kline i 05/21/2004 WELTMAN WEINBERG REIS By: Deputye IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION j DISCOVER BANK Plaintiff vs. GEOFFREY S. DUNKLE Defendant No. 04-2267 CIVIL 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. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W W R#03462547 Judgment Amount $ 7,349.93 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. GEOFFREY S. DUNKLE Defendant TO THE PROTHONOTARY: Civil Action No. 04-2267 CIVIL PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, Geoffrey S. Dunkie, above named, in the default of an Answer, in the amount of $7,349.93 computed as follows: Amount claimed in Complaint $6,449.93 Interest from date of judgment at the legal interest rate of 6% per annum Attorney's fees $900.00 TOTAL $7,349.93 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' Es ire PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W W R#03462547 Plaintiff's address is: c/o Waltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7`h Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 981 Hummel Avenue, Lemoyne, PA 17043 S Y IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. GEOFFREY S. DUNKLE Civil Action No. 04-2267 CIVIL TERM Defendant IMPORTANT NOTICE TO: Geoffrey S. Dunkle 981 Hummel Avenue Lemoyne, PA 17043 Date of Notice: 41 ? 1 YOU RE 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE. GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE Cumberland County Bar Association 2 Liberty Avenue Carlisle, PA 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. o 1 l Zzan PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #03462547 ?I VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa.C.S. Section 4904 relating to unsworn falsification to authorities, that the parties against whom Judgment is to be entered according to the Praecipe attached are not members of the Armed Forces of the United States or any other military or non-military service covered by the Soldiers and Sailors Civil Relief Act of 1940. The undersigned further states that the information is true and correct to the best of the undersigned's knowledge and belief and upon information received from others. WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. IVoiczza?n, Esq ' e PA I.D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#03462547 ?. ? ? o ? ? ? c s ? ;`- _? `= `1 John B. Dougherty, Esquire Pa. I.D. No. 70680 IRA H. WEINSTOCK, P.C. 800 North Second Street Harrisburg, PA 17102 Telephone: 717-238-1657 Fax: 717-238-6691 Attorneys for: PLAINTIFFS ROXANNE SCHAUER and THOMAS E. SCHAUER, her husband Plaintiffs, vs. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNA. No. 05-2267 HYDRAULIC FITTINGS CO., INC. and UNCLE BOB'S SELF STORAGE, Defendants CIVIL ACTION - LAW PRAECIPE TO THE PROTHONOTARY: Please mark the above-captioned matter settled, discontinued and ended. Respectfully Submitted, IRA H. WEINSTOCK, P.C. 800 North Second Street Harrisburg, PA 17102 Phone: 717-238-1657 B A JOHN B. DOUG ERT Atty. I.D. No. 69272 DISCONTINUANCE AND NOW THIS ,b-A-day of , 200$ the above-captioned case is hereby marked settled, discontinued and ended. 12 PR HON By: R • CERTIFICATE OF SERVICE AND NOW, this 29th day of April, 2008, I, John B. Dougherty, Esquire, attorney for the Plaintiffs, hereby certify that I served the within PRAECIPE this day by mailing the same to: Joel I. Herzfeld, Esquire Salmon, Ricchezza, Singer & Turchi, LLP 1700 Market Street, Suite 3110 Philadelphia, PA 19103 Enrico C. Tufano, Esquire Wilson, Elser, Moskowitz, Edelman & Dicker, LLP Independent Square West The Curtis Center, Suite 1130 East Philadelphia, PA 19106-3308 B A Cjj?f"? JOHN B. D UG RTY C0 :CF t..3 CJ' --C IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. GEOFFREY S DUNKLE Defendant No. 04-2267-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 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#3462547 L.P.A. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 04-2267-CIVIL TERM GEOFFREY S DUNKLE Defendant 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. By: James C. V PA. I. D.#42 WELTMA 1400 KOp f Esquire INBERG & REIS CO., L.P.A. uilding Avenue Pittsbu PA 15219 436 SeF4-77955 (412) 4 Sworn to and subscribed WWR #3462547 before me this _a? d?y\of December, 2008 P QOMMONV tALTH OF PENNSYLVANIA Notarial Seat Heidi J. Kelly, Notary Public City Of Pittsburgh, Allegheny Cowty My Commission Expires Nov. 4,2W9 Member, PennsylvaN3 Assrcietion of Notaries 19t 0 obi .4 c