The URL can be used to link to this page

Home My WebLink About11-1216tl r _?TJ i1 [I - ((#??il.oj n F I PEE -2 Pri 12: 5 1 LIMBERLAIND C0U TY P EN HI5Y LVAN'IA IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff NO: I I- /,Q/& C`Vi I Teo, vs. JONATHAN BEMIS COMPLAINT IN CIVIL ACTION Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: `Benjamin W. Lawrence,209032 WELTMAN, WEI:NBERG & REIS CO., L.P.A. 325 CHESTNUT STREET SUITE 501 PHILADELPHIA, PA 19106-2614 215-599-1500 FAX: 215-599-1505 08719004 C A Jer JIH os 49a,oo PO amt C? 5c?1 ? ?8b dsysyy IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No JONATHAN BEMIS 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 not_'_ce 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: JONATHAN BEMIS 527 LEWISBERRY RD NEW CUMBERLND, PA 17070 3. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX3207 . 4. Defendant made use of said credit card and has a current balance due of $10529.13 , as of September 15, 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 September 15, 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 , JONATHAN BEMIS INDIVIDUALLY , in the amount of $10529.13 with interest at the rate of 28.99050 per annum from September 15, 2010 plus attorneys' fees of $125.00 , and costs. t Benjami W. Lawrence,209032 WELTMAN, WEINBERG & REIS CO., L.P.A. 325 CHESTNUT STREET SUITE 501 PHILADELPHIA, PA 19106-2614 215-599-1-500 FAX: 215-599-1505 08719004 C A Jer JIH This law firm is a debt collector attempting to collect this debt for our client and any information obtained will be used for that purpose. New Balance Minimum Payment Due Account Number ending in 3207 DISCOVER $10,529.13 $10,529.13 Enter Amount Enclosed Below Payment Due Date $ C DUE IMMEDIATELY 08 SDSN8A01 0000771 JONATHAN BEMIS 527 LEWISBERRY RD NEW CUMBERLND PA 17070-2314 Address, eanail at telephone change$ Print change in space above, or go to Discover.com. Print your eanad address to receive important Account information and special offers. Go pepwkm and make your account iMomretbn mom secure wkh pawword- protected only you can access. Loom more at discover corn1papsrless. PO BOX 6103 111 1611111111111161111 CAROL STREAM IL 60197-6103 )r))u))uun?))r)rr)rn?r??nnr))))uur))r))uur))u)u)? 000001986458427210576105291300000001052913 Discover More Card Account Summary closing Doh: November 8, 2008 Page 1 of 1 Account number ending In 3207 Previous Balance $10,529.13 Payment Due Date December 7, 2008 Payments And Credits 0.00 Minimum Payment Due $10,529.13 Purchases + 0.00 Credit Limit $8,800.00 Cash Advances + 0.00 Credit Available $0.00 Balance Transfers + 0.00 Cash Credit Limit $0.00 Finmce Charges + 0.00 Cash Credit Available $0.00 New Balance - $10,529.13 Casbba& Bonuse Cashback Bonuats Anniversary Month: August Opening Cashbock Bonus Balance New Cashback Bonus This Period C,ashbock Bonus Bakines, $ 0.00 + 0.00 $ 0.00 How Can We Help You? 1. Visit Disoswr cem to pW yaw bill for no coat, i your latest Account information, earn and redeem rewards and more it's your choice - 3 ways to help 2. Cal 1-8004)ISCOVER (347-2683) kx fast, easy sel4ervice Please have your Discover Card available. dons or to speak with a Customer Service Account Manager You 3. Write us at Discover Card, PO Box 30943, For TDD (assistance for hearing impaired) we reverse side Sail Lake City, UT 84130 Transactions $0 Fraud Liability Guaranies Use your Discover Card with confidence. Information For You While we are permitted under the Cardmembe Agreement to increase the APRs on your Account because your payment was stet we have chosen not to do so at this time. W* have terminated, however, any introductory or promotional rote on purchases and any special balance transfer rate, and applied the - I rd APR fur purchases to your outstanding balance of purchases and balance transfers. However, we reserve the right to i woose the APRs on your Account if you fail to pay the minimum payment due by the payment due date. See the Default Rate Plan section of the Cardmember Agreement for details. Finance Charge Summary 8719004 Nominal Transaction , AvVap ai l ANNUAL EKV41AGE P ANNUAL AGE =8 F iDa ?? r odic R ot" RATES W E CHARGES FINANCE 9M12[l`L- current billing period: 5 days Purchases $0 0.07942% 28.99% F 28.99% $0 $0 Cash Advances $0 0.07942% 28.99% F 28.99% $0 $0 previous billing period: 3 days Purchases $0 0.07942% 28.99% F 28.99% $0 none The rates that apply to your Account are either fixed (F) or they may vary M as noted above. sosNSAD1 0000771 ZX7 sus At S ill s s ba ? a 1? r its ? SRI ? s V ,b it's ft 11211 Hill n fill a ?a Alit x n ? ? a A ZVI s # a Allailis Dam s ZZ 131 bg+ $ s a a sJ1 Z 111 12., Z ?_ # - r g# -ta a oil fit a 8 sec, 22, 2010 3.22PM VERIFICATION No, 976" P. 2 The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsifications to authorities, that he/she is Natasha Szcz, iel (Name) Account ManaRe-r? of DFS Services LLC, serv ice jig agent for Discover Bank, plaintiff (Title) Company) herein, that he/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 his/her knowledge, information and belief. W WR#8719004 Client Account #6011002300103207 Name JONATHAN BEMIS FILED-OFFICE THE ROTHONOTAM 2011 FEB 23 AM 9: 21 WELTMAN, WEINBERG & REIS CO., L.P.A UMBER -AND CoUNT Y BY: Michael J Dougherty, Esquire FWAVY 4or Iaintiff(s) I.D. No. 76046 325 Chestnut Street, Suite 501 Philadelphia, PA 19106 Phone: 215.599.1500 Fax: 215.599.1505 File # 08719004 DISCOVER BANK vs. JONATHAN BEMIS CUMBERLAND County Court of Common Pleas No.: 11-1216 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss the above matter without prejudice. WELTMAN, WEINBERG & REIS CO., L.P.A. By hael J DouKerty, Esquire ,Attorney for Plaintiff r