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Home My WebLink About10-3305Y ~ 1 f~}V •... i~l i-~.s Z~10 i~~Y 16 Fri 4= 53 CVIYi~~..~',y,~',,'rlll v`,rUi` IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: (p - .3305 CtV t 1 T~~ vs. COMPLAINT IN CIVIL ACTION CHRISTOPHER A BREAM 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 08251563 C A Pit EMR \v ~'~ +~5~8830 E~ a~ aa9(P TN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No CHRISTOPHER A BREAM 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 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, DISCOVER BANK is a corporation with offices at 6500 NEW ALBANY ROAD NEW ALBANY OH 43054 . 2. Defendant is adult individual(s) residing at the address listed below: CHRISTOPHER A BREAM 1289 HIGH ST BOILING SPRGS, PA 17007 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX3534 . 4. Defendant made use of said credit card and has a current balance due of $4697.82 as of March 11, 2010 . 5. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff. 6. Plaintiff is entitled to the addition of interest at the rate of 27.2400 per annum on the unpaid balance from March 11, 2010 A copy of Plaintiff's Statement is attached hereto, marked as Exhibit "1" and made a part hereof. 7. Plaintiff avers that the Agreement between the :parties provides that Defendant will pay Plaintiff's attorneys' fees. 8. Plaintiff avers that such attorneys' fees will amount to $125.00 . 9. 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 CHRISTOPHER A BREAM ,individually in the amount of $4697.82 with interest at the rate of 27.240% per annum from March 11, 2010 plus attorneys' fees of $125.00 and costs. F - James C Wa ro t,42524 WELT EINBERG & REIS CO., L.P.A. 436 Se en h Avenue, Suite 1400 Pitts rg PA 15219 (412) 43 -7955 FAX: 41 338-7130 0825 56 C A Pit EMR This law firm is a debt collector attem~t/1ng to collect this debt for our client and any information obtained ill be used for that purpose. DISCOVER ;~+, ~0~2o1DO'° s',~r as aymerit Due New Balance ub97.Bs 15 SDSN6A01 0005692 CHRISTOPHER BREAM 1289 HIGH ST BOILING SPRGS PA 17007-967b PO BOX 6103 INusl~uusrlls~rlnlull CAROL STREAM IL 60147-6103 Addrou, email ortelephons chorrgeR lrllulluunl(lrlulnrlrllnurllllnu~llrllunrllnlull Go to www.Diseover.cam or print change in space oboes. 0000019864588133020370469?8200000DD0469782 tats: February 1, 2010 - tDosing Dais: Fsbt Discover More Card Account Summary cardntentber sine Account number ending in 3534 Provious Balance j4,697.82 Payments And Crodita 0..00 Purchases + 0.00 Balance Trcrnsfen + 0.00 Cash Advances + 0.00 F'neuee t3rairges + 0.00 Other Fees t + 0.00 New Ba a 4,697.82 See Finance Charge Summary section Following frnnaoefions for derailed APR inforrnofion Credit L'ns 53,600.00 Credd tine Avaik~ble - - 30:00 - Cash Adwnce Credit tins j0.00 Cash Advance Credit tJrre Available j0.00 t Sss transaction detail for a description of arty (ass charged. `^""""`'^ """°' Anniversary Month March Opening Cashb«k Bonus Bakmce j 0.00 New Cashbook Bonus This Period + 0,00 tashbadc eerrv: eelanc. j o.oo To learn more, 109 in orvrww:Diecover.oarrr and sekcr Rewords Account Number ending in 3534 Enter Amount Enekxed Bebw ~~ Please make check payable to Discover Cord. Minimum payment due Includes a past due amount of 1936.00. Go paperless and make your accotutt information more secure vAth pt~aswor+d- pprrotected statements anfy you cart acxsss. Learn mare at discovercamlpapefless. j4,697.82 j4,a97.82 March 10, 2010 Manage Your Account Online at www.D'tscover.corrt • Securely access statements and free arline tools, pay bins online and track and view ad transaeHons simply and easily ~• Mako your mousy worth mors~-find easy ways to cam . and redeem cash awards • NEWT Acosss your «count securely drrough your mobile phone 3 Easy Ways to Contact Us 1. Access your account securely at www.Diecewr.cam 2. Caq 1-SOt1DISCOVER (1-800.3426831 Please haw your Diswver0 card avails 3. Write to us at Discover, PO Box 30943, SaMlake Ciy,ln 84130 For TDD (Telseommunications Device For the Dsa9 assistance, please call 1.800.347-7449. ,Transactions D M~ PDa ~_Fi~al~tc~ Chcrge- Summ.Qry - __.-__ __ __ _ _____ - Nominal Other Average Daily ANNUAL ANNUAL Periodic Fee Daily Periodic PERCEN(AGE PERCENTAGE FWAWCE currerd billing period: 15 days J~4} Rates RATES RATES CHARGES Purchases j0 0.074639E 27.249: V 27.24% SO j0 Cash Advances j0 0.08216% 29.99% V 29.99% j0 jo •V .Variable Rafe Information For You Notwithstanding ihs payment due dale on this statement, if you paid the New Balance on your previous billing statement by ;the Payment Due Date shown on that biNing statement, vw will not impose Periodic Finanu Charges on new purchases first ',appearing on this billing statement, or arty portion of a new purchase, paid within 25 days of the Ckuing DaM on this billing staMmenf. $25 rse side. D~C•e~VER VERIFICATION The undersigned does hereby verify subject to the penalties of l 8 PA.C.S. §4904 relating to unsworn falsifications to authorities, that he is James Ball (Name) Team Lead of DFS Services LLC ,plaintiff herein, that (Title) (Company) he is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of his knowledge, information and belief. WWR# 8251563 Christopher A. Bream ~~3534 4' ..i.'~.. :_ T ;~ _ - ~ ,;,.~Y~ 'l~l~ J~~~ ~%~ {~P~ ~` ~ F L.i , ~ `~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DNISION DISCOVER BANK Plaintiff No. 10-3305 CNIL TERM vs. PRAECIl'E TO SETTLE, DISCONTINUE AND END WITH PREJUDICE TO REFILE CHRISTOPHER A BREAM Defendant(s) FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Lyndsay E Rowland, Esquire PA LD. #205520 WELTMAN, WEINBERG & REIS CO., L.P.A 1400 Koppers Building 436 Seventh Avenue Pittsburgh; PA 15219 (412)434-7955 WWR#8251563 DIS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CNIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 10-3305 CNIL TERM CHRISTOPHER A BREAM Defendant(s) PRAECIPE TO SETTLE DISCONTINUE AND END WITH PREJUDICE TO REFILE TO THE PROTHONOTARY OF COUNTY: Settle, Discontinue and End With Prejudice to Refile the above-captioned matter upon the records of the Court and mark the costs paid. WELTM~IN, WE$NBERG &~IS CO., L. BY~ C''~J .;~~~/1'. Lyndsay E Row nd; ~squi e PA LD. #20552,{1 WELTMAN, ~ INBERG & REIS CO., L.P.A 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412)434-7955 WWR#8251563 Sworn to and subscribgd Before me the 20 ~ Day of JN ~ f COMMON- ' ~PENNSYLVAryIA Wiyn~ A, , Nonry Pubik ~~ ~, ANl~hrfly County y1+fi113! X014 9~F, ~