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Home My WebLink About10-3871 F i M , ' U ,? - 2010'1'u F" ' 4 7 Cum' L 4, IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. ASHLEY JANEL BROWN Defendant No : ?d - 98 7/ COMPLAINT IN CIVIL ACTION 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 08332794 C A Pit EMR J M2.0o C/-=e IY4068/D 2? ?sb8 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No ASHLEY JANEL BROWN 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 f 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: ASHLEY JANEL BROWN 325 EUTAW AVE NEW CUMBERLAND, PA 17070 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX0985 . 4. Defendant made use of said credit card and has a current balance due of $1904.49 , as of April 10, 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 April 10, 2010 . A copy of Plaintiff's Statement is attached hereto, marked as Exhibit 11111 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 , ASHLEY JANEL BROWN individually , in the amount of $1904.49 with interest at the rate of 28.990% per annum from April 10, 2010 plus attorneys' fees of $125.00 , and costs. James c WELTMAN 436 Sev Pittsb (412) FAX: 4 08332 9 This law firm is a debt collector attemp our client and any information obtained a ro t, 42,524 INBERG & REIS CO., L.P.A. Avenue, Suite 1400 PA 15219 955 38-7130 A Pit EMR to collect this debt for be used for that purpose. ®'???`yt?? New Balance Minimum Payment Due Account Numk-gr ondi in 0985 $0.00 8319.00 Enter Amount EnelaWl Wow Payment Due Date $ September 29, 2008 31 SDSN6A01 0001474 ASHLEY BROWN 1603 PRIMROSE LN DAUPHIN PA 17018-9594 Go peperless and make your account information more secure with psesword- Erdacted sWornertta only you can access. Learn more at discover.corNpaparless. PO BOX 6103 (ILanlbasnnlbsarlldlrsl CAROL STREAM IL 60197-6103 Address, email or telephone chonge9 Print change in space rru.il????nlm??l?nu??lllnarrlld?nn??ln?n?? above, or go to Discover.com. Print your e-mail address to receive important Account information and special offers. 000001986458210265829000000000000000035900 Discover More Card Account Summary Closing Date: August 31, 2008 page 1 of 1 ;Account number ending in 0985 Previous Balance $1,904.49 ;Payment Due Date September 29, 2008 Payments And Credits 1,904.49 Minimum Payment Due $359.00 Purchases + 0.00 jCreditLimit $1,500.00 Cash Advances + 0.00 ;Credit Available $0.00 Balance Transfers + 0.00 ;Cash Credit limit $800.00 Finance Charges _ + 0.00 ;Cash Credit Available $0.00 New Balance $0.00 Cashback Bonuse Opening Cashback Bonus Balance $ 0.00 New Cashback Bonus This Period + 0.00 Cashbock Bonus Balance $ 0.00 - iCashback-$onusWAnnivers------------- I -------------------------------------------------------- ;Month: August ;How Can We Help You? 1. Visit D'acovereom to pay your bg for no cost, view your latest Account information, earn and ,deem rewards and more ;It's your choice - 3 ways to help 2. Call 1-80OZISCOVER 1347-26831 For fast, sway self service Please have your Discover Cord available. options or to speak with a Customer Service Account Manager . Write ua of Discover Card, PO Box 30943, 3 For TDD assistance for hearing impaired) see reverse side ? ( Sob Lake City, UT 84130 ;Transactions $0 Fraud Liability Guarantee Use your Discover Card with confidence. Trans. Post Dare Dale Payments and Credits Aug 31 Aug 31 INTERNAL CHARGE?OFF $ -1,904.49 EXHIBIT ---------------------------------------- - ------------- ;finance Charge Summary Nominal Transaction Average Daily ANNUAL ANNUAL Periodic Fee Daily Periodic PERCENTAGE PERCENTAGE RNANCE F04ANCE Balances Rotes RATES RATES CHAI;6ES CHARGES ,current billing period: 19 days ;Purchases $O 0.07942% 28.99% F 28.99% $0 $0 ;Past Purchases $O 0.07942% 28.99% F 28.99% $O $O Kash Advances so 0.07942% 28.99% F 28.99% $O $O 'The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above. 8338794 VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsifications to authorities, that she is Jodi Preston (Name) Account Manager _ of DFS Services LLC , plaintiff herein, that (Title) (Company) she 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 her knowledge, information and belief. (Signs e) WWR# 8332794 Ashley J. Brown ??0985 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor ~~~Htr at ~~~at~br~{~~~ ~, .'~.`; 4FFIGE O~ 'HE SrERIFF F1lE'~t ' '1~ Thy r~ `~. ":~z:.~r~Y 2010 JAY i 7 Pl~r 2~ 4~ ~~.. t ...1~ 4('~ Discover Bank vs. Case Number Ashley Janel Brown 2010-3871 SHERIFF'S RETURN OF SERVICE 06/15/2010 07:00 PM -Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 15, 2010 at 1900 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Ashley Janel Brown, by making known unto herself personally, at 325 Eutaw Avenue, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to her personally the said true and correct copy of the same. r~/~ NOAH CLINE, DEPUTY SHERIFF COST: $43.30 June 16, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF (cj CountySuite Sheriff. Teleosoft.. Inc.