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Home My WebLink About13-0739:'r' r ,1 . t ~ ~ `~~ ~ 3 a~`~' j r IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION Discover Bank, Through Its Servicing Agent, DB Servicing Corporation Plaintiff vs. CATRINA M HAMILTON-DRAGER Defendant _ 3 ,vi~ No: COMPLAINT IN CIVIL ACTION FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan,47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 30067963 C A Pit SJS ,~ ~jo3. ~Pd a~ ~(~~# /v9/y~~o e~a~~ y~g COMPLAINT 1. Plaintiff, Discover Bank, is a banking institution organized under the laws of the State of Delaware and maintains a business address of 12 Reads Way, New Castle, DE 19720. 2. DB Servicing Corporation is the servicing affiliate for Discover Bank, f/k/a Greenwood Trust Company, an FDIC-insured Delaware State bank. As the servicing affiliate, DB Servicing Corporation performs a variety of services for Discover Bank including, business management services in support of Discover Bank business lines, including, among other things, credit cards, deposits, personal loans and student loans, customer service, collections, credit risk, collection of delinquent accounts and other support services. The collection of delinquent accounts includes the right to forward the account to the attorneys and/or collection agencies for collection and to file suit on Discover Bank's behalf. 3. At all times pertinent hereto, DB Servicing Corporation is the servicing affiliate for Discover Bank, in reference to Defendant account, which is the subject of this litigation. 4. Defendant is adult individual(s) residing at 3573 RITNER HWY NEWVILLE, PA 17241 5. Defendant applied for and received a credit card bearing the account number XXXXXXXXXXXX2843. 6. Defendant made use of said credit card and has a current balance due of $10138.09. A copy of Plaintiff's STATEMENT is attached hereto, marked as Exhibit "1". 7. Defendant is in default by failing to make monthly payments when due. As such, the entire balance is immediately due and payable to Plaintiff. 8. Although repeatedly requested to do so by Plaintiff, Defendant has willfully failed and/or refused to pay the balance due the Plaintiff. WHEREFORE, Plaintiff prays for Judgment in its favor and against Defendant, CATRINA M HAMILTON-DRAGER, INDIVIDUALLY, in the amount of $10138.09 with interest at the statutory rate of 6.00 o per annum from date of judgment and costs. u William T. Molczan,~4f/437 WELTMAN, WEINBERG ~ REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh, PA 15219 (412) 434-7955 FAX: 412-338-7130 WWR# 30067963 C A Pit SJS 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. DISCOVER New Balance ~ Minimum Payment Due S0.00 $1,757.00 Payment Due Data October 25, 2012 Account Number ending in 2843 Enter Amount Enckued Bebw ~~ 30 SDSN6A01 0008561 CATRINA M HAMILTON-DRAGER 3573 RITNER HWY NEWVILLE PA 17241-9120 Text APP to DISCOV' to receive a Nnk to our free mobile app and pay your bitl In seconds from anywhere) PO BOX 6103 Illrssllsrrrrllsllsrslrsrll CAROL STREAM IL 60197-6103 Address, email or tskphono charge$ I~Ilnllin~nlllili~lnil~ll~nnllllrunlli~l~n~ill~~~I~~~ Go to www.Dixowr.com or print charge in space above. {y ;{ }a] Ysu ,a"''i SU~II 0000019864579259799480000000000000D0175700 „®._~ - sphmbar 30, 2012 page 1 of 2 uaro: ~eptembsr 11, ~V I Z - Closing Doh: S Discover More Card Account Summary Account number ending in 2843 Previous Balance 610,138.09 Payments And Credits 10,138.09 Purchases + 0.00 Balance Transfers + 0.00 Cash Advances + 0.00 Fees Charged + 0.00 Interest Chorgod + 0.00 New Ba onto _ -0.00 See Interest Charge Cakulotion section following transactions for detailed APR information Credit Line S 14,400.00 'Credit Line Available So;oo Cash Advance Credit Lino 56,000,00 Cash Advance Credit line Available 60.00 VV.r~W4A wrrva Anniversary Month February Opening Cashback Bonus Balance S 0.00 Nsw Cashback Bonus This Period + p.00 Cashback bonus 8olance S 0.00 To learn more, b9 in al www.Diswwr.com Payment Information Naw Balance 50.00 Minimum Payment Due 61,757.00 Payment Dus Date October 25, 2012 tole Payment Wamirg: If ws do rrof receive your minimum payment by the date listed above, you may haw to poy a late fee of up to 535.00 and your purchase and balance fransfer APRs For new transactions may ba increased up to the Penally APR of 16.24% variable. Manage Your Account Online at www.Discover.com Securely access sfatemenh and free online tools, poy bills online and track and view all transactions simply and easily Make your money worth morel-Find easy ways fo earn and redeem cash rewards NEWT Access your account securely through your mobile phone 3 Easy Ways to Contact Us 1 Access your account securely at www.Discowr,com 2. Call 1-800-DISCOVER (1-804347-26831. Please have your Dixover®cord available. 3. Write to us at Discover f'O Box 30943, Sak lake City, UT 841 §0 (Not a payment address) For paymenh, se send to addross on remiBance or Dixover, PO Fox 6103, Card Sfream, IL 60197.6103 for TDD (Telecommunications Device for the DeoE) assistance, please mil 1.804347-7449. Transactions ~s. P ~ Payments and Cr~edrts Sep 30 Sep 30 INTERNAL CHARGE-OFF 5 10,138.09 F»s TOTAL FEES FOR THIS PERIOD S 0.00 I^ro^n Charged TOTAL INTEREST FOR THIS PERIOD 6 0.00 2012 Totals Year-to-Date TOTAL FEES CHARGED IN 2012 S 235.00 TOTAL INTEREST CHARGED IN 2012 808.27 30067963 NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION D' VC~ Poperless siotements meon less clutiler, more convenience Easily access up to 24 months of downloadable, password protected statements. • See your statement as soon as it's available rather than wait for it to arrive in your mailbox. • Get helpful payment reminders through email or text messages on your mobile phone. • Print a paper copy of your statement anytime. • Sign up today at fhscovercom/papsrfess 02010 Diacovnr Bonk, AAember FDIC PAPFR.03 10 ~', Z rn A O_ 0 00 m ~_ N O 30067963 Qu@StlOns~ Visit www.Discowr.com or call 1-800-DISCOVER (1-800-347-2683. DISCOVER DISCOVER ~ ttpeysto ~ CATRINAMHAMILTON-DRAGER _~ ~~ _ Account number ending in 2843 page 2 of 2 Interest Charge Calculation Your Annval Percentage Rafe (APR) is the annual interest rah on your account. Currant 8iling Period: 10 days TYPE CrF BALANCE ANNUAL PERCENTAGE BALANCE SUBJECT TO INTEREST CHARGE RATE (APR) INTEREST RATE Purchases 11.24Yo V $0 $0 Cash Advances 23.99% V $0 $p V =Variable Rate Addiliona) bnportaM Momsation - - See year Cordneml»r Agr«m«rt. Your Cardmember Agreement contains all the terms of your Account. lost or stolen cards. Report immsdiatelyl Cap 1-800.347.2683. What To Do If You Tbisrk You Firsd A Mistake On Your Statstr-sent If you think there is an error on your statement, write to us at: Dixovsr, PO Box 30421 Sah Lake City, UT 84130.0421 In your IeMer give us the following information: Account information: Your name and account number Dollar amount: The ddlar amount of the suspected error Descri tiara of Problem: IF you think there is an error on your bill, dexribe what you believe is wrong and why you believe d ii a mists e. You must contact us within 60 days offer the error appeared on your statement. You must notify us of any potential errors train writin .You may call us, but if you do we are not required to investigate any potential errors and you may hove to pay the amount in question. While we investigate whether or not there has been an error, the following are true: We cannot fry to collect the amount in queston, or report you as delinquent on that amount. The charge in question may remain on your statement, and we may continue to charge you iMerssf on that amount. But, if we determine that we made a mistake, you will not have to pay the amount in question or any interest or other fees related to that amount. While you do not have to pay the amount in question, you are responsible for the remainder of your balance. We can apply any unpaid amount against your credit limit. Your RiaMs ff Yov Me DiuaNsfied f~Ht Your Credit Cord Purclsasas If you are dissatisfied with the goods or services that you have purchased with your credit card, and you have hied in good faith ro correct the problem with the merchant, you may have the right not to pay the remaining amount due on the purchase. To use This right, all of the following must be frue: 1 The purchase must have been made in your home state or within 100 miles of your current mailing address, and the purchase price must have been more than $S0. (Note: Neither of Ihese are necessary if your purchase was based on an advertisement we mailed to you or if we own the company that sold you the goods or services.) 2. You must have used your credit card for the purchase. Purchases made with cash advances from an ATM or with a check that accesses your credit card account do not qualify. 3. You must not yet have fully paid for the purchase. tf all of the criteria above are met and you are stiff dissatisfied with the purchase, contact us in wrifina ot: Dixover PO Box 30945, Sah lake Ci yt , UT 84130-0945 Whits we investigate, the some rules apply fo the disputed amount as dixussed above. Aker we finish our investigation, we will tell you our decision. At that point, if we think you owe an amount and you do not pay we may report you as delinquent. Poyrnents. You may pay all or part of lrovr Account balance rn any time. However, you must pay at least the Minimum Payment Due by the Payment Dus Dah. Send only Your payment and the top portion of this statement in the envelope provided. Do not send cash. By sending your check as dexribed above, you authorize us to use information on your check to make an electronic fund hansfer from your account at the financial institution indicated on your check or to process the payment as a check transaction. IF payment rs processed as an elechonic fund fransfer, the honsfer will be for the amount of the check. When we use information from your check to make an eecfronic Fund transfer, funds may be withdrawn from your account as soon as the sumo day we receive your payment, and you will not receive your check back from your financial institution. The processing of yyour payment may be delayed if you send cash, correspondence or other items with yyour payment, if you send the payment to any other address or if you use an envelope other than the one provided. Payments recervsd in proper form at our processing facility by 5PM local time on any dayy will be credited to your Account as of that day. Payments received at our processing Facility after 5PM kxal time will be credited to your Account as of ihs next day If you have mispk:ced your envelope, send your payment to Discover, PO Box 6103 Carol Sheam, IL 60197.6103. Pkaase albw 710 days for delivery. If your payment is returned unpaid, ws reserve the rig~it fo resubmit it as an elechonic debit. 30067963 NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION D'Q CD You con pay r monthly Minimum PaymeN Due, a a greater amount that does rat exceed your current Account balance, over the or you can setup automatic payments iMovgh a customer service repttisentatiw by calling 1-800.347. 683. Automatic payments will bs deducted on the Payment Dw Doh unless yvu request a recurring pa snt date (e. .the 15th day of the month) that «cun bsfaro your Payment Dw Dote. If your acltedulsd payment date falls on a weekend or bank holiday, your payment will be pr«esssd the business day prior to the weekend or bank hoiday. In order to schedule monthly payments b tele you veil need this statement and your bank «count information. You will bs asked ~toprovide the last four (4~digifs of Ifie social security number of the pnmary borrower. By pprroviding those numbers as your electronic signature, you wJl bs agreeing to this authorization to allow us and your bank to deduct each pa ent you authorize, in the amount selected by you, ham your bank account. You also aulhonz~ us to initiate debit or credit errtries to your bank account, as appIccable, to correct an error in the processing of such payment. You can cancel a scheduled payment by phone at 1-800.347.2683 or by mail at Discover, f'O Box 30421 Sah lake Cily, UT 84130A421, howwer we must receive notice at least Three business days in advance of the scheduled payment. IF your payments may vary in amount, we will tell you on each monthly billing shfemsnt when your payment will be made erect how much it will be. You must ensure that sufficient funds are available in your bank «count, and all tronsoctions must comply with U.S. ksw. You can set automatic payments for (i) statement New Balance, (ii) statement Minimum Payment Dw, (iii) statement Minimum Payment Due plus a fixed dollar amount, or (iv) a fixed doNar amount. If your xhedulsd faced payment is not enough fo cover the Minimum Payment Dw os listed on your monthly billinrrgg stabnrent, your scheduled payment for that month wiU be increased to cover the Minimum Payment Dw. IF the scheduled payment cs~reater than Nte Minimum Payment Due, any excess will be a ied in accordance with your Cardmember Agreement. IFyour scheduled pa enf is greater than the New Babnce on your billing statement, that payment will be processed only for the amount of your New Balance. Your automatic ppaayment amount maybe less than the amount nrdc on the periodic statement based on credits or payments aker the Cbsing Date. If you enroll by phone in our automatic payment service, please fill-in the folowing blanks below and retain the authorization for your records. Amount: ^ Full Pay ^ Min Poy ^ Min Pay + S ^ Fixed Pays Bank Routing #: ,Bank Account #: ,Frequency; C~sdit Reporting. We may report informdion about your Account b credM bureaus, late payments, missed payments, or other defauks on your Account may bs roFlected in your credit report. Ws normally report 1M status and payment hisrory of your Account to credit reporting agencies each month. If you be it eve Ifwt our roper} cs inaccurate or incomplNe, please write us al the following address: Discover, PO Box 15316, Wilmington, DE 19850.5316. Please indicate your name, address, home telephone number and Account number P rrUsrest Wa begin to impose interest charges on a harrsaction fee or irrferest chaggs from the day we add it fo the daily 6alonce. We confines to impose interest charges until you pay t~is total amount you owe us. You can avoid paying interest on Purchases as described below. However, you cannot woad paying interest on Balance Transfers or Cash Advances. How to Avoid Pa in Interest on Purchases Gross Period" psi eve a ncs on your prwaus i rng statement by the Payment Dw Dafe shown on that billing statement, we we I not impose interest charges on new Purchases or any portion of a new Purchase, pad by the Payment Due Date on your current billing statement. Now Purchases ors Purchases that first appear on the eurronf billing statement. How We Payments May Impact Your Grass Period you not pay your eve once m e«u~m remit en, depending on the balance fo which we apply your payment, you may not get a grace period on new Purchases. How We CaleulaN InNrosf (yrarges Doty bahsrrn AAellrod (irdrrdirg current tonsactissrs): We cakulate interest charges each billing period by first figuring firs "daily balance" for a«h Tronsoction Category. Transaction C ies include standard Purchases, standard Cash Advances and diFFeront promotional balances, such as Balance Trans rs. flow Ws Figure firs Doilr balance f+or 6aslr Trwrsactiorr Category We start with the be~inning balance for a«h day. Ths beginning balance For tfre first day of the billing period is your balance on the ost day of your prwious billing period We add any interest charges «creed on the previous day's daily balance and any new hansactions and Tess. Wa add an new transactions or foes os of the later of the Transaction Dots or the first day of the billing period in which the transaction or fee posted to your Account. We subtract any new credits and payments. We make other adjustmenh (including tFase adjustments requirod in fhs "Paying Interest" section). How We Figure Yow Totd rrhrsat Graryes We muhiply the daily balance For a«h Tronsoction Category by its daily ppeerriodic rate. We do this For a«h day in the billirr~ period. This gives us 1Fte interosl charges for each Transaction CotegorY. To get a daily periodic rate, we divide the APR that applies to the Transaction Category by 365. We add up all the daily interest clrorges. The sum is the total ineerost charge for fhs billing period. How We krclrrde Fees We add Balance Transfer Fees to the applicable Baksncs Transfer Transaction Caleg~y~ We add Cash Advance Fees to the applicable Cash Advance Transaction Category. We add all other fsssio firs standard Purchase Transaction Category. baance Subject to Interest Refs. Your statement shows a Balance Subject b Intsrosf Rave. It shows this for each transaction category. The Balance Subject to Interest Rote is the average of drs doily balances during the biNing period. Crodit balances. IF your Account has a crodit baance, the amount is shown on Nrs front of your billing statement. A credit balance is money that is owed to you. You may make charges against this amount iF your Account is open. We will send you o refund of any romaimrtg balance of 51.00 or more after 6 morrlhs, or os otherwise requued by applicable law. Fes TDD (Tehxommunications Device ter tiro Dealt ossisterrce, please caN 1800.347-7448 Discover may monitor and/or record telephone calls between you and Discover roprewnfatiws for quality assurance p8®887963 Tice Discover®card is issued by Discover Bonk, Member FDIC RZNFE001 0 z a 0 °o _m N O C>2uestions? vlsll ~ivwvv.D;.~gt, or DISCOVER call )-800-DISCOVER (l •800-347-2683). ' ~ F ~ , (Name) VERIFICATION Legal Placement Account Manager (Title) of DB Servicing Corporation, servicing affiliate of Discover Bank, (Company) does hereby verify, under penalty of perjury and subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsifications to authorities states, that he/she is a duly authorized representative of plaintiff herein and authorized to make this verification, and that the facts sets forth in the foregoing Complaint are true and correct to the best of his/her knowledge and information and that he/she is personally familiar with the account and the relationship between Discover Bank and DB Servicing Corporation. That Discover Bank, f/k/a Greenwood Trust Company, is aFDIC-insured Delaware State bank, and its servicing affiliate DB Servicing Corporation, extends credit through issuance of the Discover Card. As the servicing affiliate, DB Servicing Corporation performs a variety of services for Discover Bank including business management services in support of Discover Bank business lines, including, among other things, credit cards, deposits, personal loans and student loans, customer service, collections, credit risk, collection of delinquent accounts and other support services. The collection of delinquent accounts includes the right to forward the same to the attorneys and/or collection agencies for collection and to file suit on Discover Bank's behalf. Both DB Servicing Corporation and Discover Bank are wholly owned subsidiaries of Discover Financial Services. Date ~ - ~ I - ~ ~_ Catrina M Hamilton-Drager XXXXXXXXXXXX2843 WWR#30067963 r (Signature) DB Servicing Corporation servicing affiliate for Discover Bank PO Box 3025 New Albany, OH 43054 SHERIFF'S OFFICE OF CUMBERLAND COUNTY ;LEU-OF Ronny RAnderson F�,p,Ui' TAR" Sheriff f F THE PROTHONO-�AR �p CL�u�bpp�dp� Jody S Smith 2013 MAR 18 AM 9: 56 Chief Deputy ! T Richard W Stewart °°; CUMBERLAND COUNTY Solicitor OFFICE OF T14C SkERIFF PENNSYLVANIA Discover Bank Case Number vs. Catrina M Hamilton-Drager 2013-739 SHERIFF'S RETURN OF SERVICE 03/11/2013 07:30 PM-Deputy Noah Cline, being duly sworn according to law, served the requested Complaint& Notice by"personally"handing a true copy to a person representing themselves to be the Defendant,to wit: Catrina M Hamilton-Drager at 3573 Ritner Highway,West Pennsboro Township, Newville, PA 17241. NOAH CLINE, DEPUTY SHERIFF COST: $64.00 SO ANSWERS, � 4z �� March 12, 2013 RON R ANDERSON, SHERIFF (c)CountySuite Shenff,Teleosoff.Inc. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION-LAW Discover Bank, ) Through Its Servicing Agent, ) DB Servicing Corporation, ) Plaintiff, ) Case No.: 13.739 MW vs. 7J Catrina M. Hamilton-Drager, ) Defendant. ) c. NOTICE TO PLEAD w " You have been sued in Court . If you wish to defend against the claims set forth in New Matter, you must take action within twenty (20) days after this Answer and New Matter 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 the Defendant' s Answer and New Matter or relief requested by the Defendant. You may lose money or property or other rights important to you. YOU SHOULD TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFCE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA (717) 249-3166 Catrina M. Hamilton-Drager 3573 Ritner Hwy Newville, PA 17241 (717) 776-0259 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION-LAW Discover Bank, ) Through Its Servicing Agent, ) DB Servicing Corporation, ) Plaintiff, ) Case No.: 13.739 vs. ) Catrina M. Hamilton-Drager, ) Defendant. ) ANSWER AND NEW MATTER And now, comes the Defendant, Catrina M. Hamilton- Drager, pro se, who answers the Plaintiff' s Complaint as follows : 1 . Paragraph 1 is admitted. 2 . After reasonable investigation, I am without knowledge or information sufficient to form a belief as to the truth of Paragraph 2, which is therefore denied. 3 . After reasonable investigation, I am without knowledge or information sufficient to form a belief as to the truth of Paragraph 3, which is therefore denied. 4 . Paragraph 4 is admitted. S. I cannot confirm that the account number, as listed in Paragraph 5, is mine. Paragraph 5 is therefore denied. To the contrary the allegations contained in paragraph 5 of Plaintiff' s Complaint are specifically denied and strict proof (original signed contract) to the contrary are demanded at trial . In further answer to Plaintiff ' s Complaint, Plaintiff has failed to produce an executed contract or give any evidence of a verbal agreement between the Plaintiff and Defendant. 6. Although my name is on the STATEMENT that is marked as Exhibit "1", the allegations contained in paragraph 6 of Plaintiff' s Complaint are specifically denied and strict proof (copies of signed sales slips and copies of all statements since the account was opened) to the contrary are demanded at trial. In further answer to Plaintiff' s Complaint, Plaintiff has failed to attach any statements showing use of said credit card by Defendant . 7 . Paragraph 7 is denied. To the contrary the allegations contained in paragraph 7 of Plaintiff' s Complaint are specifically denied and strict proof to the contrary are demanded at trial. In further answer to Plaintiff ' s Complaint, Plaintiff has failed to attach a copy of the signed contract . 8 . Paragraph 8 is denied. To the contrary the allegations contained in paragraph 8 of Plaintiff' s Complaint are specifically denied and strict proof to the contrary are demanded at trial . NEW MATTER 9. That Plaintiff does not have an original or copy of an executed contract between the Plaintiff and Defendant upon which this suit is brought. 10 . That Plaintiff does not have any statements original or otherwise showing purchases and/or payments made by the Defendant upon which this suit is brought. ll . That Plaintiff does not have a breakdown of how they arrived at the current balance said owed by Defendant upon which this suit is brought . WHEREFORE, the defendant requests that judgment be entered against the plaintiff. Respectfully Submitted, ,"' J�n 4 (JI—I r= Defendant Catrina M. Hamilton-Drager 3573 Ritner Hwy Newville, PA 17241 (7 17) 776-0259 Defendant I verify that the statements made in this Answer and New Matter are true and correct . I understand that false statements herein are made subject to the penalties of 18 Pa. C. S. §4904, relating to unsworn falsification to authorities . Date: March 26, 2013 4V t, &A- I )J/ gnature Catrina M. Hamilton-Drager Print Name IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION—LAW Discover Bank, ) Through Its Servicing Agent, ) DB Servicing Corporation, ) Plaintiff, ) = cc ) Case No.: 13.739 /-03 Zz .y...{ VJ. i'� ^O �.' i 6 Catrina M. Hamilton-Drager, ) co Defendant. ) z D a>C- �'tat" _ .M"' co ..-...1 f CERTIFICATE OF SERVICE , I, Catrina M. Hamilton-Drager, hereby certify that I have mailed by U.S. mail, first class, postage prepaid on this 26th day of March 2013, a true and correct copy of the Answer and New Matter with Notice to Plead to the person at the address indicated: William T. Molzcan,47437 WELTMAN, WEINBERG&REIS CO., L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh,PA 15219 (412)434-7955 Fax: 412-338-7130 Date: March 26, 2013 Catrina M. Hamilton-Drager 3573 Ritner Hwy Newville, PA 17241 (717)776-0259 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION-LAW Discover Bank, ) Through Its Servicing Agent, ) DB Servicing Corporation, ) - Plaintiff, ) =� --u -0 Case No.: 13.739 ,,r- -- ' CD VS. ) - ; Catrina M. Hamilton-Drager, ) ry rM, ry � r-' Defendant. ) IMPORTANT NOTICE You are in default because you have failed to take action required of you in this case. Unless you act within ten (10) 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 TARE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFCE SET FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP: Lawyer Referral Service Cumberland County Bar Association 32 South Bedford Street Carlisle, PA (717) 249-3166 Catrina M. Hamilton-Dra r 3573 Ritner Hwy Newville, PA 17241 (7 17) 776-0259 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY,PENNSYLVANIA CIVIL DIVISION—LAW Discover Bank, ) Through Its Servicing Agent, ) DB Servicing Corporation, ) ZZ Plaintiff, ) rn00 a.> M_= Case No.: 13.739 VS. ) --- cr< ca Catrina M.Hamilton-Drager, ) � '"! CD Defendant. ) CERTIFICATE OF SERVICE I, Catrina M. Hamilton-Drager, hereby certify that I have mailed by U.S. mail, first class, postage prepaid on this 15a' day of April 2013, a true and correct copy of Defendant's NOTICE OF INTENT TO TAKE DEFAULT JUDGMENT to the person at the address indicated: William T.Molzcan,47437 WELTMAN, WEINBERG&REIS CO.,L.P.A. 436 Seventh Avenue, Suite 1400 Pittsburgh,PA 15219 (412)434-7955 Fax: 412-338-7130 Date:April 15,2013 Catrina M. Hamilton-Drager 3573 Ritner Hwy Newville;PA 17241 (717)776-0259 WELTMAN, WEINBERG & REIS CO., L.P.A. BY: William T. Molczan, Esquire I.D. No. 47437 436 7th Ave Ste 1400 Pittsburgh, PA 15219 Phone: (412) 434-7955 Fax: (412) 338-7130 File # 30067963 WTM/SJS Attorney for Plaintiff(s) Discover Bank, Through Its Servicing Agent DB Servicing Corporation CUMBERLAND County Court of Common Pleas vs. CATRINA M HAMILTON-DRAGER PRAECIPE TO DISMISS WITH PREJUDICE No.: 13-739 CIVIL TO THE PROTHONOTARY: Kindly dismiss the above matter with prejudice . WELTMAN, WEINBERG & REIS CO., L.P.A. By William T. Molczan, Fire Attorney for Plaintiff 11 101 111 1111111111111111111111111111111111111111111111111111111