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Home My WebLink About04-4410Our File No. 183358 ATTORNEYS FOR PLAINTIFF ERIC M. BERMAN, P.C. BY: Eric M. Berman, Esquire, I.D. 83698 BY: Robert M. Kline, Esquire,I.D. 56479 198 Allendale Road, Suite 306 King of Prussia, PA 19406 (610) 265-7720 COURT OF COMMON PLEAS ......................................... X COUNTY OF CUMBERLAND DISCOVER BANK c/o ERIC M. BERM3LN, P.C. : TRIAL DIVISION 198 Allendale Road, Suite 306 : King of Prussia, PA 19406 : CIVIL ACTION vs. : Term DALE G BEERS 217 FRONT 3FL BOILING SPRGS, PA 17007 0266 ......................................... x No. uvlo (SXal 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 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 this complaint or for any other claim or relief required 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. 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. LAWYER REFERENCE SERVICE COUNTY OF CUMBERLAND BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PA 17013 800-990-9108 Our File No. 183358 ATTORNEYS FOR PLAINTIFF ERIC M. BERMi~N, P.C. BY: Eric M. Eerman, Esquire, I.D. 83698 BY: Robert M. Kline, Esquire, I.D. 56479 198 Allendale Road, Suite 306 King of Prussia, PA 19406 (610) 265-7720 ......................................... X COURT OF COMMON PLEAS : COUNTY OF CUMBERLAND DISCOVER BANK c/o ERIC M. BERM~/~, P.C. : CIVIL ACTION 198 Allendale Road, Suite 306 : Term King of Prussia, PA 19406 : VS. DALE G BEERS 217 FRONT 3FL BOILING SPRGS, PA 17007 0266 COMPLAINT 1. Plaintiff, DISCOVER BANK , is a DELAWARE STATE BANK authorized to do business in the Commonwealth of Pennsylvania with its place of business at 3311 MILL MEAJDOW DRIVE, MILLIARD, OH 43026. 2. The Defendant(s), DALE G BEERS , resides at 217 FRONT 3FL , BOILING SPRGS, PA 17007-0266. 3. There is due from the Defendant(s) the sum of $4,114.33 for credit extended by Plaintiff to Defendant(s), acct. no. 6011002960701407, and which such credit was drawn and used by the Defendant(s). Defendant(s) is in default for failure to make payments for such use. 4. The Plaintiff has made demand upon the Defendant(s) for payment of monies in the sum of $4,114.33 advanced to Defendant(s) through Defendant(s) use of the above-referenced credit account, but Defendant(s) has failed and refused to pay the said sum or any part thereof. 5. All applicable credits, if any, have been duly applied to Defendant(s) credit account. WHEREFORE, Plaintiff claims of the Defendant(s) the sum of $4,114.33 plus interest, attorneys fees and costs which are justly due and owing from the Defendant(s) to the Plaintiff. ERIC M. BERMA~ P.C. Dated: JULY 30, 2004 BY: ERIC M. BE~J~N, ESQUIRE BY: ROBERT M. KLINE ESQUIRE SPACEBNW-ZN Attorneys for Plaintiff VERIFICATION Eric M. Berman, Esquire, being duly sworn according to law, deposes and says that he is the Principal attorney of Eric M. Berman, P.C., attorneys for the Plaintiff, and/or Robert M. Kline, Esquire, being duly sworn according to law, deposes and says that he is an associate attorney with said firm, and as said attorney, is authorized to take this verification on its behalf, and that the facts in the Complaint as set forth therein are true and correct to the best of his knowledge, information and belief. I verify that the statements made in the within instrument are true and correct. I understand that false statements are subject to the penalties of 18 Pa C.S.A. Section 4904 relating to unsworn falsifications to authorities. ERIC M. BERMAN, ESQUIRE ROBERT M. KLINE, ESQUIRE Dated: JULY 30, 2004 SPACEBNW-ZN SHERIFF'S RETURN - REGULAR CASE NO: 2004-04410 P COMMONWEALTH OF PENNSYLVAiqIA: COUNTY OF CUMBERLAND DISCOVER BANK VS BEERS DALE G CPL. MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BEERS DALE G the DEFENDANT , at 1159:00 HOURS, on the 13th day of September, 2004 at 217 FRONT STREET 3RD FLOOR BOILING SPRINGS, PA 17007 by handing to DALE G BEERS a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 33.18 09/14/2004 ERIC BERMAN Sworn and Subscribed to before By:~~. me this /~ ~ day of -/}-~thon~tary ' : '. ~. .... ::., _ ?.--~.:1,,.1 ~ t-.,_~. ] .]i. .~ ".d ~.r,, .-. ;":.: . ;- ....:, ! .. r.~ -:.';~!-!~.'~ ._ · :' : '.'.' .'.. ~'A ~ :'.! ~' ':"*. : ' :.'.. ','..i '. !.~.~ .... . £.:h~l '~ '" ';;'~J. '.: 'i ':'.: !' ' ~"-' ;' ' : ~· '~."., ~'".'~'"'.. .':~j,'!!:'L':"-.. w,t'?'!r .:1: ' ...... '!''~,...''~'*. ....... ' · .... :.. ]' ..':,- ',' :'.'.,It ...... . · .",; i .'," '.:--'~.='l ~.-;: ."'-,'-.: -.,..! .... :'"~ -]'"'"""- - ' - - :." ", :': ~- ,: ....... r .'.:..:'.'~... ~-"'' ~'..:.-. r, -'?- · · r:.- -, COURT OF COMMON PLEAS .......................................... X COUNTY OF CUMBERLAND .9f, Al_~nd~,l~' Read, Suite 212 : rs'. : No. 04-4410 NOTICE OF INTENTION TO TAKE DEFAULT JUDGMENT TO: DALE G BEERS 21.7 FRONT 3FL BOILING SPRGS, PA ~7007--0266 IMPORTANT NOTICE YOU ARE IN D~FAULT BECAUSE YOU HAVE FAIILED 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 NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BE~DW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORFD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT A~ENCIES THAT MAY OFFEK LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. COUNTY OF CUMBERLAND BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PA 17013 800-990-310~ ,... ERIC M. BERMAN, P.C. ERIC M. BERMAN, P.C. Attorneys for Plaintiff. Attorneys for Plaintiff By: Eric M. Berman, Esquire By: Robert M. Kline, Esquire SPACEJUD- ZH '.:' : ]~ ,'.. ~ . . ...........