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Home My WebLink About02-0684 Our File No. 153115 ~ATTORNEYS FOR PLAINTIFF ERIC M. BERMAN, P.C. BY: Eric M. Berman, Esquire, I.D. 83698 BY: Ron Z. Opher, Esquire, I.D. 57507 198 Allendale Road, Suite 306 King of Prussia, PA 19406 (610) 265-7720 DISCOVER BANK c/o ERIC M. BERMAN, P.C. : 198 Allendale Road, Suite 306 : King of Prussia, PA 19406 : : VS. : : K M HARTZ : COURT OF COMMON PLEAS COUNTY OF CUMBERLAND TRIAL DIVISION CIVIL ACTION Term NOTICE 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 OR FIND OUT WHERE YOU CAN GET LEGAL HELP. AVISO Le han demandado a usted en la corte. Si usted quiere defenderse de estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plaza al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o en persona o con un abagado y entregar a la corte en forma escrita sus defensas o sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. A demas la la corte puede decidir a favor del demandante y requiere que usted compla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATEMENTE. SI NO TIENE ABOGA 0 SO NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. LAWYER REFERRAL SERVICE, COUNTY OF CUMBERLAND BAR ASSOCIATION Address: 2 LIBERTY AVE., CARLISLE, PA 17013 Tel.: 800-990-9108 ~ur File No. 153115 ATTORNEYS FOR PLAINTIFF ERIC M. BERMAN, P.C. BY: Eric M. Berman, Esquire, I.D. 83698 BY: Ron Z. Opher, Esquire, I.D. 57505 198 ALLEN-DALE ROAD, SUITE 306 KING OF PRUSSIA, PA 19406 (610) 265-7720 DISCOVER BANK c/o ERIC M. BERMAN, P.C. 198 Allendale Road, Suite 306 King of Prussia, PA 19406 VS. COURT OF COMMON PLEAS COUNTY OF CUMBERLAND CIVIL ACTION Term : No. : : K M HARTZ : COMPLAINT 1. Plaintiff, DISCOVER BANK , is a DELAWARE BUSINESS TRUST licensed to do business in the Commonwealth of Pennsylvania with its place of business at P.O. BOX 8003, HILLIARD, OH 43026. 2. The Defendant(s), K M HARTZ , resides at 806 MEADOW LN , CAMP HILL, PA 17011-1545. 3. There is due from the Defendant(s) the sum of $2,169.94 for credit extended by Plaintiff to Defendant(s), acct. no. 6011002230252116, 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 $2,169.94 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. Ail applicable credits, if any, have been duly applied to Defendant(s) credit account. WHEREFORE, Plaintiff claims of the Defendant(s) the sum of $2,169.94 plus interest, attorneys fees and costs which are justly due and owing from the Defendant(s) to the Plaintiff. Dated: DECEMBER 28, 2001 SPACE-AQ ERIC M.~ BY: ERIC M. BERMAN, ESQUIRE BY: RON Z. OPHER, Esquire Attorneys for Plaintiff VERIFICATION RON Z. OPHER, ESQUIRE, being duly sworn according to law, deposes and says that he is of Counsel to the Law Firm of Eric M. Berman, P.C., and/or 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 as said attorney, he 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 Dated: DECEMBER 28, 2001 RON Z. OPHER, ESQUIRE SPACE-AQ ATTORNEY: ACCOIINT NUMBER: BALANCE: CARDMEMBER (S): BERMAN 6011002230252116 $2169.94 K MHARTZ STATE OF OHIO COUNTY OF FRANKLIN G. Rogers, personally appeared before me, this day and after being duly sworn, according to law, upon his/her oath and says: THIS person is a Legal Placement Account Manager for DISCOVER FINANCIAL SERVICES INC., the servicing agent of DISCOVER BANK, an FDIC insured Delaware State Bank. THAT, in their capacity as Legal Placement Account Manager, Affiant has control over and access to records regarding the account of this debtor; further, that the Affiant has personally inspected said account and statements regarding the balance due on said account. These Records are kept in the normal course of business. THAT the undersigned Affiant being duly sworn deposes and says that the policies and procedures of DISCOVER BANK and it's servicing agent, DISCOVER FINANCIAL SERVICES, INC. are in accordance with applicable federal ard state consumer and credit laws. THAT the annexed statement of account, in favor of DISCOVER BANK, is a tree and correct statement and there is now due and owing to DISCOVER BANK, exhibit A is a copy of the terms of the account which we forwarded with the charge card to the Card member(s). THAT to the best of the Affiant's knowledge and belief the defendant is employed in civilian life and by reason thereof is not engaged in the military service of the United States and is a resident of the State and of the County in which this action has been filed. THAT this affidavit is made on the basis of the Affiant's personal knowledge and in support of Plaintiff's suit on account against said Debtor. Sworn and Subscribed before me, This day of Thursday, August 09, 2001. SHERIFF'S RETURN - REGULAR CASE NO: 2002-00684 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS HARTZ K M DOUGLAS DONSEN , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon the HARTZ K M DEFENDANT , at 1720:00 HOURS, on the 27th day of February , 2002 at 31 FARGREEN ROAD CAMP HILL, PA 17011 by handing to K.M.HARTZ 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: Docketing 18.00 Service 19.32 Affidavit .00 Surcharge 10.00 .00 47.32 Sworn and Subscribed to before me this /3 ~ day of --}~, ~/~ ~ A.D. · - So Answers: R. Thomas Kline 03/04/2002 ERIC BERMAN By: ~--~~~ Deputy Sheriff