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Home My WebLink About10-3904~. ~~F TNc P,~'~; '~~`'~, ~RRY ~~,~ 2010 JU~~ 15 PIS I ~ 06 ~- , P~ ~ti~ ~:~YL4't~i.Jir IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaint i f f No : ~Q - ~07 1~1v i l T~f'r'1 vs. COMPLAINT IN CIVIL ACTION JESSICA L ERICHSEN 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 08332853 C A Pit EMR pp P D AT"rN ~,rt 4 to 088p1o 2~~3~~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No JESSICA L ERICHSEN 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: JESSICA L ERICHSEN 1 COLLEGE AVE GRANTHAM, PA 17027 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX2932 . 4. Defendant made use of said credit card and has a current balance due of $2673.48 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 12.490% per annum on the unpaid balance from April 10, 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 JESSICA L ERICHSEN ,individually in the amount of $2673.48 with interest at the rate of 12.490 per annum from April 10, 2010 plus attorneys' fees of $125.00 and costs. v - James C. a ro ,42524 WELTMAN INB & REIS CO., L.P.A. 436 Sev nt Avenue, Suite 1400 Pittsb rg PA 15219 (412) 34 7955 FAX: 12- 38-7130 0833 853 C A Pit ENII2 This law firm is a debt collector attem t' g to collect this debt for our client and any information obtaine ill be used for that purpose. New Boksncs Minimum Payment Due DISC®VER so.ao s419.00 Payment Dw Dote AprR 28, 2010 31 SDSN6A01 0000561 JESSICA ERICHSEN 1 COLLEGE AVE PO BOX 5479 GRANTHAM PA 17027-9800 Addroas, e.mad or telephone chonge8 Cio to www.Dixoves•.com or print change in space above. Account Number ending. in 2932 Enter Amount Enckssed Below Go paperbss and t-mlte yotx accolxtt information more aecu~e wRl1 peaeaiad- protecfed atatornerlb aNy ytou can aaoaas. cam more att dtacovercontlpapetNas. PO BOX 6103 iiinsilinnsNsus~~siiss~ CAROL STREAM IL 60197-6103 ~~~~u~~uun~iir~n~nririinm~i~~uurUiQuurHni~rii ODDOD1986459148549433000000000000000D419D0 Opening Date: March 11,2010 - Clawing Dale: March Discover More Card Account Summary Cardmsmbar since Account number ending in 2932 i Previous Balance 52,673.48 Payments And Credits - 2,673.48 Purchases + 0.00 fldancs Transfers + 0.00 Cash Advances + 0.00 Finance Charges + 0.00 ~ CMMr Fsss t + 0.00 Balance 0.00 i See Finance Charge Summary section following transactions for dtailed APR Information i Credit Line 51,750.00 - ~ Ctrdittirle AvaNable- ' - - - - - - - - - - - - - ~ - - - - - -SOS>Q " Cash Advance Credit Line 51,100.00 ~ Cash Advance Credit Lins Availabb 50.00 i t See hansadion detail for a description of a^Y fees charged Cos C gOnuse AMlvKxuy Month November Opening Cashback Bonus Balance 5 0.00 New Cashback Bonus This Period + 0.00 i ~ Casbbadc Bonus Balance 5 0.00 i ~ To Isom more, loo in a~ www.Dixowr.asm and rslsel Rewards i 3 ~, TU lu page r a ~ Payment information New Balance 50.00 Minimum Payment Due 5419.00 Payment Due Dats April 28, 2010 tote payment Warning: If we do not recent your mir-Imum payment by the date listed above, you may haw b pay a lah fee of up to 539.00. Manage Your Accotmt Online at wvwv.D'acowr•com • SecuroFy oceesa statements and free ar-Nne tools, pay bills online and hack and view all iwrsae8ora simply and eosfy • Maks your money worth moron-Bred vary ways b earn and redeem cash rowards • NEWT Access your account securely Iluaugl- your -- rnabtlepi~at,e--------------------------------------- 3 Eosy Ways to Contact Us 1. Access your account securely at www.Disoew-.aus 2. Call l•800-DISCOVER X1.800.347-268, 3) . Please have your Dixovsr0 card awl 3. Write to us of Dixover PO Box 30943, Sah Lake City, UT 841 r30 For TDD (Telecommunieotions Davies for N» Deof~ assistance, please call 1-800-347-7449. ;Transactions Trons. Post mot. ate. Payrrrents and Credits Mar 31 Mar 31 INTERNAL CHARGE•OFF ~ -2,673.48 ;Finance Charge Summary A iDa~ly~ P~iiodic ~ current billing period: 21 days J}cslanees RaFes Nominal P~ER~ JTAGE RATES P~ERC~AGE RATES od-er PS~IM i Purchases 50 0.03422% 12.49% V 12.499'• 50 50 Cash Advances 50 0.06299% 22.99% 22.99% 50 50 V .Variable Rate i EXNIB~T 83~ s. side. DIS~~~ GR 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. (Signa e) WWR# 8332853 Jessica L. Erichsen '6011003339332932 FILED-OFFICE OF THE PROTHONOTARY 2010 DEC I PM 2: 20 C13?? ??? SY?LVAa A TY P IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. JESSICA L ERICHSEN Defendant(s) No. 10-3904 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: Benjamin R Bibler, Esquire PA I.D. #93598 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#8332853 DIS Y IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 10-3904 CIVIL TERM JESSICA L ERICHSEN Defendant(s) PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF Cumberland COUNTY: SIR: Kindly settle, discontinue and end without prejudice to refile the above-captioned matter upon the records of the Court and mark the costs paid. WELTMAN, WEINBERG & AEIS CO., L.P.A. By: `:C ' _'- Benj in Bibler, squire PA I . # 598 WEL N, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 SWORN TO AND SUBSCRIBED befor e this day of , 2010 ?i _)6e NOTARY PUBLIC Ri ON% G. NMI, Ras TWp„ Amp" CpanyMlpR NOV• 1 ?Oi4