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Home My WebLink About10-3680Mt 20(11 JG'~~ -t, PP; 12= 52 r~, ~;,~:.'r'L'V~t, ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: !O - 3~$Q ~~~~ (.`7-~n.,~ vs. COMPLAINT IN CIVIL ACTION VINCE E COLLER 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 08253886 C A Pit KMJ S ~'9~.00 1 cL (~~~ c,~,r 4o7vs3 S IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No VINCE E COLLER 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 OU'T' 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: VINCE E COLLER 262 WALNUT BOTTOM RD CARLISLE, PA 17013 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX5853 . 4. Defendant made use of said credit card and has a current balance due of $10376.11 as of March 12, 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 28.990% per annum on the unpaid balance from March 12, 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 VINCE E COLLER ,individually in the amount of $10376.11 with interest at the rate of 28.9900 per annum from March 12, 2010 plus attorneys' fees of $125.00 and costs. James C. WELTMAN, 436 Seve Pittsbuz (412) FAX: 4 082538 6 This law firm is a debt collector attempt our client and any information obtained W r ro t,42524 IINBERG & REIS CO., L.P.A. Avenue, Suite 1400 PA 15219 955 8-7130 A Pit KMJ to collect this debt for be used for that purpose. D'~~~ r G R Payment Due Dale Minimum Payment Due lUtanch 10, 2010 510,376.11 Nsw Balance 510,376.11 15 SDSN6A01 0003714 VINCE COIIER 262 WALNUT BOTTOM RD CARLISLE PA 17013-3739 Account Number ending in 5853 Enter Amount Enekued Bebw ~~ Please make check payable to Discover Card. Minimum y~~t due includes a past dw omouN o~2 944.00. Go paperless and make your account Intonrlatioll more secure wiffi pesaword- pro~e~ed statements oMy you can access. Lim more at discovercomlpaperkss. PO BOX 6103 'I'lll"1.111a"I'IIIIIII" CAROL STREAM IL 501`97-6103 Address, eirlall or telephone Change8 I1~~11'Illllll~l'II11~111'li'IIIIIIiu11111'IIIIIIIIIIIfllll'f t3o to www.D'acovercam or print change in apace above. 0000019864588172309601037611000000D1037611 Opening Dab: Jatuay 16, 2010 - dosing Dab: Febr Discover More Card Account Summary Carlttnsmber since Account number ending in 5853 Provious Balance 610,376.11 Payments And Credits - 0.00 Purchases + 0.00 Balance Transbrs + 0.00 Cash Advances + 0.00 Finance Charges + 0.00 CMhsr Fses t + 0.00 New Ba • 10,376.11 See finance Charge Summary section idbwing transactions For detailed APR information Credit line 68,400.00 Credit line Avaiklbls - - - - - 50.00 Cash Advance Credit line 60.00 Cash Advance Credff line Avaiksbls 60.00 t See trnnsadion detail Far a description of any fees charged. ~..uafiwcic oviws Anniversary Month September Opening Cashback Bonus Balance 6 0.00 New Coshbock Bantu This Period + 0,00 Callback Bows balance 6 0.00 To loam man, lab In at www.Dtsoowrcom and select Rewords gar J r r, cv r v t+ucJs I w f Payment Information New Balance 610,376.11 Minimum Paymsrt Dus• 510,376.11 Payment Dw Date March 10, 2010 •klciudss post due amount of 52,344.00 isle Paylnerd Wernilg: IF we do not receive your minimum payment by the date Gslsd above, you may haw fo pay a k16 Fes of up to 639.00 and your purchase APRs For new ironsoctions maybe irlasaxd up to the Defauk APR of 29.99% variable. Manage Your Al:xolult Online at www.Discover.com • Securely access slaMalenh and free online cods, pay bills online and track arld view dl fransoctions simply and easily . • _ Make your money vrortFl moron-find easy ways to sam - - - - and rodeem cash rewards • NEWT Access your aocounf securely through your mobile phone 3 Easy Ways ro Conroct Us 1. Axes your account securely at vvvvw.Dileoverean 2. CaN t-800~DISCOVER (1-800.347-2683) . Please haw your Discovsr~ card oval 3. Write to us at Diaeowr, PO Box 30943, Sale lake City, t!T 84130 For TDD (Telecorrunlslieations Device for the Deefl assiatalce, please cal 1800.347-7449. Transactions ~s. Puo~l. _ Finance Charge Summary - __ _ _ _ _ . "'~"" Nominar---- - Average Doily AtVNUAI ANNUAL Periodic Fw Daily Periodic PERCENTAGE PERCENTAGE FNANCE FWANCE YVITerd biting period: 31 days Balances Rases RATES RATES CFIARGES CFIAR(~5 Purchases ~ 60 0.07942% 28.99% 28.99X 60 SO Cash Advances 60 0.07942% 28.99% 28.9976 SO 60 V ~ Variabb Rote Information for You NoMrithstondirlg the payment due date on this statement, if you paid th• Nsw Balance on your previous biting statemerd by the Payment Due Date shown on That biting atalsmerlt, vre veil noF impose Periodic Firlarlce Charges on new purchases first appearing on this billing statement, or any portion of a new purchase, paid within 25 days of ifte Closing Data on this biting statement. 829~8~fi~ aids. D~$ClVE[~ VERIFICATION The undersigned does hereby verify subject to the penalties of 18 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# 8253886 Vince E. Coller ~~5853 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor d.°`~~tp at ~am~~rl~~~ '~;~.' ~Fi4E OF THE SHERIFF' ~~~0 ~U~ ~ ~ ~~ ~~ v4 ~~ ~ Discover Bank Case Number vs, Vince E. CoNer 2010-3680 SHERIFF'S RETURN OF SERVICE 06h 712010 08:09 PM -Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on June 17, 2010 at 2007 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Vince E. Coller, by making known unto himself personally, at 262 Walnut Bottom Road, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $33.40 June 18, 2010 TIM BIACI~ DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF ~ci GountySuite Snenff, ieleosoft, tnc.