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Home My WebLink About10-3906~. H~~Jh~l~~ 3F ?1-fF PFn=j.,n;<~;~ GARY 2Ql0 ,IUd 15 ~'~ ! ~ ~7 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER.BANK Plainti f f No : ~ p _ 3gp(o C~V ~ l TiE1'w1 vs. COMPLAINT IN CIVIL ACTION KATHERINE E RYNARD 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 08330652 C A Pit EMR $9a.oo P Q ATY`/ ~'~ dy3~~9 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No KATHERINE E RYNARD 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 ages, 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: KATHERINE E RYNARD 111 E PORTLAND ST MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX6216 . 4. Defendant made use of said credit card and has a current balance due of $6581.30 as of April 09, 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 19.990 per annum on the unpaid balance from April 09, 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 KATHERINE E RYNARD ,individually , in the amount of .$6581.30 with interest at the rate of 19.990 per annum from April 09, 2010 plus attorneys' fees of $125.00 and costs. James L:. armnrOQL, 4G5L4 WELTMAN, JEINBERG & REIS CO., L.P.A. 436 Sev Avenue, Suite 1400 Pittsbu gh PA 15219 (412) 4- 955 FAX: 4 2- 38-7130 08330 2 A Pit EMR This law firm is a debt collector attemp i to collect this debt for our client and any information obtained 1 be used for that purpose. DISC~VEt~ ~ Ba1an" 91 8D8M1tilIW1 OQ0~22 KATHERINE RYNARD 111 E PORTLAND ST MECHANiCSBURB PA 17055-3333 Minimum Payment Dw S1,136.00 PaymanF Dw Dde Apra 26, tow Address, onrail a tslaplroroe efneg~Y Go to wwwAisc~wrcem a prkr doaga in space dww. Rariodic 0 05477% 0.06573% 000001986459329282762000000000000000113600 Op4nin0 Dab: AAas+cls 6, ZO10 - ~9 Dula: 11Acrch ; Ditlcawr Ma+~ Card Account Sutlilltwry Cardro.:nb.r s~ Aeoowr number ending in 6216 Previous Baksnoa =6.581 30 Payments And Credits - 6,581.30 ~ Purdaas + 0.00 Bakxrce TramFaa + 0.00 Cash Advances + 0.00 i Rsanoa Clsaga + 0.00 CMlrar Fws t + 0.00 ~ New Sea Finance Charge Srxnmary seeHon (oNowig trarosaelions ~ For dstai{ad APR inFormdion Credit Una 55,200.00 -j Cradir{irrr Available - . - - - - ~ - - 10.00 Cash Advance CndN Una =500.00 i Cosh Adwnw Cndr lino Available s0 00 * S.e iransoetion datoii For o daeription of arty Fins darged. ~s°°~ owe Anniversexy Marh Moy Opening cashbook Bones Balaoc. 5 0.00 New Cashbaek Bonin This Period + 000 CaslrbaeFc Irsnre Nwlersoe = 0.00 To loam moo. lea N arwsswAlsmveaeem and rberRevvgrds A«ount Numbs «ding ie 62)6 Error Amarrt.Enebsed Balaw S [~ Qa p1IpN1NS Nld Irl~kia y01t ilDO0111K a/Manwds aNy 11'~ eanaCCna. ~mon st siMcolraroornlpnparlsma. PO BOX 6103 Il~uslluwllussllsllu~ CAROL STREAM IL 60197-6103 Irl~n~~uuu~l~r~n~nrlrl~nur~lllnsrs~lrllnusl~ss~u~~ 11, Zp10 1 ax 1 Payniant In~orlrtaKort Nwr Baksnce So.00 Minimum Paymanl Dw 51,136.00 Poymant Due OaN AprH 26, 2010 ~ Poyrsoset Warning: IF we do rrd reeNw your mininwm paymarr by llre dd. lislad above, you moy haw to pay a ko» Fsa of up to =39.00 and your purelwsa APRs For nave Iransociions maybe frrenasad up b the Dakruk APR aF 24 99% variabM. Mattci~o Your A~aootett Ot>Ibto at www.Daco~wroDtn • Securely access siaiernarrs and iae ardira tools, pay biNs or~irra and bade and view aN iransaciiens simply and easily • Make your money worth moat-Rnd say ways to eam end arrlsnn ~ ravvaxh _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ _ _ _ _ _'. • ~~ Apla~wss your aeoarer ~ your 3 Eery Ways io Contact Us 1. Aeoass your ocoover saoaaly d vrww.Discaserxasrs 2. CaN 1.800.OISCOVER (1.800347.2683 Pkasa haw your Diseover~oard . 3. Wrib b w d Oiseovar PO Boot 30943, Sak lake CNy, UT 841 §0 For 1DD RelsoommuniooMoros Davis For #re OsaQ assistanu, plsae caA 1-804347 7449. Transadions Try.. ~ t>«. ' P.ymants and Cledib Mar 31 Mar 31 iNTERNAI CHARGE-OFF s x,581.30 J_ ~___ ______ Finonce ~~e Summary i Avwage i ot-r[arr biNirg penod: 26 days Prxehasas :0 i Cash Advances s0 i V .Variable Role Nomind ~~~ ~~ 19.99% V 19.99% 23.99% 23.49% exe{!en -~- 50 50 50 50 83 ,,~. 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# 8330652 Katherine E. Rynard '6011003536166216 % IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK t 0 TA r? i Plaintiff No: 10-3906 CIVIL TERM VS. KATHERINE E RYNARD PRAECIPE FOR DEFAULT JUDGMENT 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 08330652 C A Pit DIP Judgment Amount $7122.53 4 4-oo PO A(-rtl C1471 W3 r 0,2g8847 DISCOVER BANK Plaintiff VS. KATHERINE E RYNARD TO THE PROTHONTARY: IN THE COUR1' OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Civil Action No. 10-3906 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant KATHERINE E RYNARD above named, in the default of an Answer, in the amount of $7122.53 computed as follows: Amount claimed in Complaint Less payments / adjustments made Interest on the remaining principa $6581.30 from April 09, 2010 to Q the interest rate of 19.990% Attorney's fees TOTAL $6581.30 $0.00 1 balance of August 03, 2010 per annum $416.23 $125.00 $7122.53 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO., L.P.A. By: James C. ro t,42524 08330652 rApit DIP Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburg A 15219 And that the last known address of the e endant is KATHERINE E RYNARD 111 E PORTLAND ST MECHANICSBURG, PA 17055 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 10-3906 CIVIL TERM KATHERINE E RYNARD NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the fo lowing Order of Judgment was entered against you on i0 (xx) Assumpsit Judgment in the amount of $7122.53 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default { ) Verdict ( ) Arbitration Award Prothonot By: KATHERINE E RYNARD 111 E PORTLAND ST MECHANICSBURG, PA 17055 Plaintiff's address is: c/o WELTMAN, WEINBERG & REIS CO., L.P.A., 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Service Members Civil Relief Act Page 1 of 2 Aug-10-2010 06:35:57 Last Name First/Middle Begin Date Active Duty Status Active Duty End Date Service Agency KATHERINE Based on the information you have furnished, the DMDC does not possess RYNARD any information indicating the individual status. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Uniformed Services (Army, Navy, Marine Corps, Air Force, NOAA, Public Health, and Coast Guard). Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The DoD strongly supports the enforcement of the Service Members Civil Relief Act (50 USC App. §§ 501 et seq, as amended) (SCRA) (formerly known as the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's status by contacting that person's Service via the "defenselink.mil" URL http://www.defenselink.mil/fack/pis/PC09SLDR.htm1. If you have evidence the person is on active duty and you fail to obtain this additional Service verification, punitive provisions of the SCRA may be invoked against you. See 50 USC App. §521(c). If you obtain additional information about the person (e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects active duty status including date the individual was last on active duty, if it was within the preceding 367 days. For historical information, please contact the Service SCRA points-of- contact. https://www.dmdc.osd.mil/appj/scra/popreport.do 8/10/2010 Request for Military Status Page 2 of 2 Vlore information on "Active Duty Status" Active duty status as reported in this certificate is defined in accordance with 10 USC § 101(d)(1) for a period of more than 30 consecutive days. In the case of a member of the National Guard, includes service under a call to active service authorized by the President or the Secretary of Defense for a period of more than 30 consecutive days under 32 USC § 502(f) for purposes of responding to a national emergency declared by the President and supported by Federal funds. All Active Guard Reserve (AGR) members must be assigned against an authorized mobilization position in the unit they support. This includes Navy TARs, Marine Corps ARs and Coast Guard RPAs. Active Duty status also applies to a Uniformed Service member who is an active duty commissioned officer of the U.S. Public Health Service or the National Oceanic and Atmospheric Administration (NOAA Commissioned Corps) for a period of more than 30 consecutive days. Coverage Under the SCRA is Broader in Some Cases Coverage under the SCRA is broader in some cases and includes some categories of persons on active duty for purposes of the SCRA who would not be reported as on Active Duty under this certificate. Many times orders are amended to extend the period of active duty, which would extend SCRA protections. Persons seeking to rely on this website certification should check to make sure the orders on which SCRA protections are based have not been amended to extend the inclusive dates of service. Furthermore, some protections of the SCRA may extend to persons who have received orders to report for active duty or to be inducted, but who have not actually begun active duty or actually reported for induction. The Last Date on Active Duty entry is important because a number of protections of SCRA extend beyond the last dates of active duty. Those who would rely on this certificate are urged to seek qualified legal counsel to ensure that all rights guaranteed to Service members under the SCRA are protected. WARNING: This certificate was provided based on a name and SSN provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report ID:0654E6DT 1 M https://www.dmdc.osd.mil/appj/scra/popreport.do 8/10/2010 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 10-3906 CIVIL TERM KATHERINE E RYNARD NON-MILITARY AFFIDAVIT The undersigned, who first duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant , KATHERINE E RYNARD is not in military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMSC), which states that the DMDC does not possess any information indicating the individual status. KATHERINE E RYNARD 111 E PORTLAND ST MECHANICSBURG, PA 17055 is not in the military service. Further Affiant sayeth naught. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff Case No. 10-3906 CIVIL TERM vs. KATHERINE E RYNARD Defendant IMPORTANT NOTICE TO: THERINE E RYNARD 111 E PORTLAND ST ECHANICSBURG, PA 17055 C/O LISA RYNARD 1719 N FRONT ST HARRISBURG, PA 17102 Date of Notice: I (oil 0 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. 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. CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA. 17013 (717) 249-3166 WELTMAN, WEINBERG & REIS CO., L.P.A By: ® Z''_ Matthew Urban P.A.I.D.# 90963 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, 1400 Koppers Building Pittsburgh, PA 15219 Phone: (412) 434-7955 8330652 A PIT H4N