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Home My WebLink About04-2575Our File No. 184505 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 COURT OF COMMON PLEAS -----------------------------------------X COUNTY OF CUMBERLAND DISCOVER BANK c/o ERIC M. BERMAN, P.C. TRIAL DIVISION 198 Allendale Road, Suite 306 King of Prussia, PA 19406 CIVIL ACTION vs. Term CHARLES KITZIG JR 300 N ARCH ST MECHANI------, PA 17055 3315 tt?a NOTICE DEPEND You have been sued in court, TO If you wish the claims set forth in the following pages, you must take action 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. 184505 ATTORNEYS FOR PLAINTIFF ERIC M. BERMAN, P.C_ BY: Eric M. Berman, Esquire, I.D. BY: Robert M. Kline, Esquire,I.D_ 198 Allendale Road, Suite 306 King of Prussia, PA 19406 (610) 265-7720 --------------------------------- DISCOVER BANK c/o ERIC M. BERMAN, P.C. 198 Allendale Road, Suite 306 King of Prussia, PA 19406 VS. CHARLES KITZIG JR 300 N ARCH ST MECHANICSBURG, PA 17055 3315 ----------------------------- 83698 56479 --X COURT OF COMMON PLEAS COUNTY OF CUMBERLAND CIVIL ACTION Term No. 04 --------X COMPLAINT 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), CHARLES KITZIG JR , resides at 300 N ARCH ST , MECHANICSBURG, PA 17055-3315- 3. There is due from the Defendant(s) the sum of $1,822.40 for credit extended by Plaintiff to Defendant(s), acct. no. 6011002130183809, 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 $1,822.40 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 $1,822.40 plus interest, attorneys fees and costs which are justly due and owing from the Defendant(s) to the Plaintiff. Dated: MARCH 01, 2004 ERIC M. PFRMAN, P.C. BY: ERIC M. BVIIAN, ES IRE BY: ROBERT M. KLINE ESQUIRE SPACEBNW-ZN Attorneys for Plaintiff Our File No. 184505 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. CHARLES KITZIG JR 300 N ARCH ST MECHANICSBURG, PA 17055 3315 -----------------------------------------X COMPLAINT 1. Plaintiff, DISCOVER BANK , COURT OF COMMON PLEAS COUNTY OF CUMBERLAND CIVIL ACTION Term _ No. 04 (2ioL I?JL?r? 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), CHARLES KITZIG JR , resides at 300 N ARCH ST , MECHANICSBURG, PA 17055-3315. 3. There is due from the Defendant(s) the sum of $1,822.40 for credit extended by Plaintiff to Defendant(s), acct. no. 6011002130183809, 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 $1,822.40 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 $1,822.40 plus interest, attorneys fees and costs which are justly due and owing from the Defendant(s) to the Plaintiff. Dated: MARCH 01, 2004 ERIC M. $ARMAN, P.C. BY: wv - ERIC M. B N, ES IRE 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 true and correct. I understand to the penalties of 18 Pa C.S.A. falsifications to authorities. made in the within instrument are that false statements are subject Section 4904 relating to unsworn ERIC M. BERMAN, ESQUIRE ROBERT M. KLINE, ESQUIRE Dated: MARCH 01, 2004 SPACEBNW-ZN ?4 SHERIFF'S RETURN - REGULAR CASE NO: 2004-02575 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS KITZIG CHARLES JR RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon KITZIG CHARLES JR the DEFENDANT , at 1819:00 HOURS, on the 9th day of June 2004 at 300 N ARCH ST MECHANICSBURG, PA 17055 CHARLES KITZIG JR by handing to 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 6.21 Affidavit .00 Surcharge 10.00 .00 34.21 Sworn and Subscribed to before me this _/L!?' day of ()U?- o2Au y A.D. C 0 tK rothonotary So Answers: R. Thomas Kline 06/10/2004 ERIC BERMAN By : 2G Deputy Sheriff SHERIFF'S RETURN - REGULAR CASE NO: 2004-02575 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS KITZIG CHARLES JR RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon KITZIG CHARLES JR the DEFENDANT at 1819:00 HOURS, on the 9th day of June 2004 at 300 N ARCH ST MECHANICSBURG, PA 17055 by handing to CHARLES KITZIG JR 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 6.21 Affidavit .00 Surcharge 10.00 .00 34.21 Sworn and Subscribed to before me this day of (?? al D9 A.D. 4 o ? rothonotary So Answers: R. Thomas Kline 06/10/2004 ERIC BERMAN By: Deputy Sheriff Curtis R. Long Prothonotary office of the Protbonotarp Cumberlanb Countp Renee K. Simpson Deputy Prothonotary John E. Slike Solicitor Q? - S 7S 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