HomeMy WebLinkAbout14-5717 Supreme Courtrof,Pennsylvania WWR# 30368146 C A Pit SSS
Cou °ofCommo':Pleas
Civil C6verShe4* ForPmthonotan'Use Ontr. ,;•
CUMBERLAND, flf COunt}: Docket No:
lit71 S t
7
The itllbrinotion collected on this form is used solely for court administration purposes. This form does not
supplement or replace the filing and service of pleadings or other papers as required br•laiv or rules of court.
Commencement of Action:
S CSX Complaint ❑ Writ of Summons ❑ Petition
E Transfer from Another Jurisdiction Declaration of Taking
DISCOVER BANK
C
Lead Plaintiffs Name: Lead Defendant's Name:
T ELIZABETH ROEDER
I
0 Are money damages requested? 0 Yes ❑ No Dollar Amount Requested: ® within arbitration limits
N (check one) [3outside arbitration limits
Is this a Class Action Suit? ❑ Yes Q No Is this an MDJ Appeal? ❑ Yes W No
A
William T. Molczan, 47437
Name of Plaintiff/Appellant's Attorney:
❑ Check here if you have no attorney(are a Self-Represented (Pro Se] Litigant)
Nature of the Case: Place an "X" to the left of the ONE case category that most accurately describes your
PRIMARY CASE.If you are making more than one type of claim,check the one that
you consider most important.
TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS
❑ Intentional ❑ Buyer Protection Administrative Agencies
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❑ Motor Vehicle ❑ Debt Collection:Other ❑ Board of Elections
❑ Nuisance ❑ Dept. of Transportation
S ❑ Premises Liability ❑ Statutory Appeal:Other
E ❑ Product Liability(does not include ❑ Employment Dispute
Mass tort) Discrimination
C ❑ Slander/Libel/Defamation ❑ Employment Dispute: Other ❑ Zoning Board
T' ❑ Other: ❑ Other:
I ❑ Other:
O
N MASS TORT
❑ Asbestos
B ❑ Tobacco REAL PROPERTY MISCELLANEOUS
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Updated 1/1/2011
�. 111E Pr;G d lolAQ ;rk:; t'
20'14 SEP 29 P I 1 2: S7
CUMBERLAND COUNTY
PE11,'NIS YL' A'111A
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff No: f% 57��
VS .
COMPLAINT IN CIVIL ACTION
ELIZABETH ROEDER
Defendant FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan, 47437
WELTMAN, WEINBERG & REIS CO. , L.P.A.
436 7th Ave Ste 2500
Pittsburgh PA 15219-1842
(412) 434-7955
FAX: 412-338-7130
30368146 C A Pit SJS
V
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff No:
VS .
COMPLAINT IN CIVIL ACTION
ELIZABETH ROEDER
Defendant FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan, 47437
WELTMAN, WEINBERG & REIS CO. , L.P.A.
436 7th Ave Ste 2500
Pittsburgh PA 15219-1842
(412) 434-7955
FAX: 412-338-7130
30368146 C A Pit SJS
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS. Civil Action No
ELIZABETH ROEDER
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 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 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, 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 ' s
account, which is the subject of this litigation.
4 . Defendant is an adult individual (s) residing at 16 MEADOWOOD PL
BOILING SPRGS, PA 17007
5 . Defendant applied for and received a credit card bearing the
account number XXXXXXXXXXXX0920 .
6 . Defendant made use of said credit card and has a current balance
due of $11318 . 83 . 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, ELIZABETH ROEDER, individually, in the amount of $11318 . 83
and costs .
W' r
William T. Molcz , 47437
WELTMAN, WEINBEY9f & REIS CO. , L. P.A.
436 7th Ave Ste 2500
Pittsburgh PA 15219-1842
(412) 434-7955
FAX: 412-338-7130
WWR# 30368146 C A Pit SJS
DISC VER Account
More Card
Account number ending in 0920
Open Date:May 7,2014-Close Date:Jun 6,2014
Cardmember Since 2007
Page 1 of 4
ACCOUNT SUMMARY PAYMENT INFORMATION
Previous Balance $11,126.94 New Balance $111318.83
Payments and Credits — $0.00 Minimum Payment Due $1,713.00
Purchases + $0.00 Payment Due Date July 2,2014
Balance Transfers + $0.00 •Includes past due amount of: S1486.00
Cash Advances + $0.00
Fees Charged + $35.00 Late Payment Warning: If we do not receive your minimum payment by the
Interest Charged + $156.89 date listed above,you may have to pay a late fee of up to$35.00 and your
New Balance $11,318.83 purchase and balance transfer APRs for new transactions may be increased up to
the Penalty APR of 21.49%variable.
See Interest Charge Calculation section following the Minimum Payment Warning: If you make only the minimum payment each
Transactions section for detailed APR information period,you will pay more in interest and it will take you longer to pay off your
Credit Line $10,000 balance.For example:
-------------------
Credit Line Available $0 16PWAP-0 afJh AbdyouuvilI'en&0?
atsi5g th t�id rontl�ch.tttat>tf, batortc spawn an f(tss ptryin_oft esfrmate91661
Cash Advance Credit Line $1,700 S}a}eMeisfbt�ttlOth.:. a �.
_.-
Cash Advance Credit Line Available $0 Only the minimum payment 27 years $29,015
You may be able to avoid interest on Purchases. If you would like information about credit counseling services,call 1-800-347-1121.
See reverse for details.
REWARDS
Anniversary Month
Cashback Bonus® February
517
17
Opening Balance $ 0.00
Your FICO°Credit Score on 6/1/14. New Cashback Bonus This Period + S 0.00
Redeemed This Period —S 0.00
More at Discover.com
Cashback Bonus Balance $ 0.00
Please make check payable to Discover. You are overlimii. To learn more,log in at Discover.com
Pay the sum of the Minimum Payment Due plus the remaining
overlimit amount of$1318.83.
Make Check payable to Discover NOTICE:SEE REVERSE SIDE FOR IMPORTANT INFORMATION
Please fold on the perforation below,detach and return with your payment
�Gyn76f CtD1iJp6>t� ,� 'Pay 0F11the Rci. Pho- - Account number ending in 0920
Pl asz{4i'pot F6lcl: cliff�r'�ttrpft: � �t3caver�cafin: � f`����7268� Minimum Payment Due $1,713.00
liiiil il���ll'I�I�Illlil��tlillllll�illilll�lll��llll�li�lllli l New Balance $11,318.83
Payment Due Date July 2,2014
ELIZABETH ROEDER Amount enclosed $
16 MEADOWOOD PL
BOILING SPRIGS PA 17007-9449
PO BOX 71084
CHARLOTTE NC 28272-1084
3036$1461 Internet payments must be received by 5PM ET to be credited as of the some day
Address,e-mail or telephone changed?Note changes on reverse side e p
000001986459973172426113188300800000171300 EXHIF
ELIZABE-TH ROEDER Account number ending in 0920 Open Date:May 7,2014-Close Date:Jun 6,2014 Page 2 of 4
Important Information You must ensure that sufficient funds are available in your bank account,and
See your Cardmember Agreement.Your Cordmember Agreement all transactions must comply with U.S.low.
contains all the terms of your Account.
You can set automatic payments for: (i)statement New Balance,(ii)statement
Lost or stolen cards.Report immediatelyl Call 1-800-347-2683. Minimum Payment Due,(iii)statement Minimum Payment Due plus a fixed
What To Do!f You Think You Find A Mistake On Your Statement dollar amount,or(iv)Other dollar amount. If your scheduled"Other dollar
amount'payment is not enough to cover the Minimum Payment Due as listed
If you think there is Terror on your statement,write to us at: Discover,PO
Box 30421,Solt Lake City,UT 84130-0421. You must write to us within 60 will on your monthly billing statement,your scheduled payment for that month
days after the error appeared on your statement. You may call us,but if you
payment is greater then the Minimum Payment Due,any excess will be increased to cover the Minimum Payment Due. !f the scheduled
be
do we are not required to investigate any potential errors,and you may have pah
to pay the amount in question. The Billing Rights Notice further explains your applied in accordance with your Ca lance o eyAgreement.It your scheduled
rights. Please see your Cordmember Agreement or visit payment is greater than the New Balance on your billing statement,that
https://discover.com/billingHghis for a copy of this notice. payment will be processed only for the amount of your New Balance.Your
automatic payment amount may be less than the amount indicated on She
Payments.You may pay all or part of your Account balance at any time. billing statement based on credits or payments after the Close Date.
However,you must pay at least the Minimum Payment Due by the Payment If you enroll by phone in our automatic payment service,please fill-in the
Due Date.Send only,your payment and the bottom portion of this statement If following blanks below and retain the authorization for your records.
in the envelope provided after affixing postage.Payments sent without proper g _
postage will be returned to the sender.Do not send cosh. If you pay by Amount: 0 Full Pay E1Min Pay UMin Pay+ $
check,you authorize us to use information on your check to make an
electronic fund transfer fromyour account at the financial institution indicated Q Other AmovniS Bank Routing#:
on your check or to process the payment as a check transaction.If a payment Bonk Account#
is processed as on electronic fund transfer,the transfer will be for the amount
of the check.When we use information from your check to make on Monthly on the D Payment Due Date ❑Close Dote
electronic fund transfer,funds may be wiihdrown from your account as soon
as the some day we receive Your payment,and you will not receive your El Day of month(insert dale)
check bock from your financial institution.
The processing of your payment may be delayed if you send cash,corres- Credit Reporting.We may report information about your Account to credit
pondence or other items with your payments,if you send the payment to any bureaus.Late payments,missed payments,or other defaults on your Account
other address,or if you use an envelope other than the one provided. may be reflected in your credit report.We normally report the status and
Payments received in proper form at our processing fociliiy by 5PM local time payment history of your Account to credit reporting agencies each month.If
on any day will be credited to your Account as of that day.Payments received you believe that our report is inaccurate or incomplete,please write us at this
at our processing facility after 5PM local time will be credited to your Account address:Discover,PO Box 15316,Wilmington,DE 19850-5316.Please
as of the next day.If you have misplaced your envelope,send your payment include your name,address,home telephone number and Account number.
to Discover,PO Box 6103,Carol Stream,IL 60197.6103.Please allow 7.10
days for delivery.If your payment is returned unpaid,we reserve the right to Paying Interest.Your due date is at least 25 days offer the close of each
resubmit it as on electronic debit.Payments made online or by phone will be billing period (at least 23 days for billing periods that begin in February).We
credited as of the day of receipt if made by 5 PM Eastern time. will not charge you any interest on Purchases if you pay your entire balance
by the due date each month.We will begin charging interest on Cosh
You con pay your monthly Minimum Payment Due,or a greater amount that Advances and Balance Transfers as of the later of the Transaction Date or the
does not exceed your current Account balance,over the telephone or you can first day of the billing period in which the transaction posted to your Account.
setup automatic payments through a customer service representative by
calling 1-800-347-2683.Automatic payments for the billing period shown How We Calculate Interest Charges,We Use the Daily Balance Method
on your statement will be deducted on the Payment Due Date shown on that (including current transactions)to calculate the Balance Subject to Interest
statement,or the next automatic payment date referred to on your statement, Rate. For more information,please call us of 1-800-347-2683.
unless you request a recurring payment date(e.g the 15`day of the month)
that occurs before your Payment Due Date or Close Date.If your scheduled Balance Subject to Interest Rate. Your statement shows a Balance Subject
payment date falls on o weekend or bank holiday,your payment will be to Interest Rafe. It shows this for each transaction category. The Balance
processed the business day prior to the weekend or bank holiday.In order to period to Interest Rote is the average of the daily balances during the billing
schedule monthly payments by telephone,you will need this statement and
your bank account information.You will be asked to provide the lost four(4) Credit Balances. If your Account has a credit balance,the amount is shown
digits of the social security number of the primary borrower.By providing on the front of your billing statement. A credit balance is money that is owed
those numbers as your electronic signature,you will be agreeing to this to you. You may make charges against this amount if your Account is open.
authorization to allow us and your bank to deduct each payment you We will send you a refund of any remaining balance of S 1.00 or more after
authorize,in the amount selected by you,from your bank account.You also 6 months,or as otherwise required by applicable law,or upon request made
authorize us to initiote debit or credit entries to your bank account,as to the address in the Contact Us section on page 3 of your billing statement.
applicable,to correct on error in the processing of such payment.You can
concel a scheduled payment by phone of 1-800-347-2683 or by mail at Balance Transfers.Balance Transfers are offered at our discretion and
Discover,PO Box 30421,Salt Lake City,UT 84130.0421;however,we must occrue interest at the standard purchase rate une(esswe tell you otherwise.
receive notice of least three business days in advance of the scheduled Discover may monitor and/or record telephone calls between you and
payment.If your payments may vary in amount,we will tell you on each Discover representatives for quality assurance purposes.
monthly billing statement when your payment will be made and how much it
will be. The Discover®card is issued by Discover Bank,Member FDIC. TL23N
CHANGE OF ADDRESS
If correct on front,do not use.Please print clearly in blue or block ink,in the space provided.
Street Address Home Phone
Work Phone
City �7 Email
36 t6146
To make changes to your address, email or telephone number,visit Discover.com
Continued on next page
DISC VER- Discover More Card
Account number ending in 0920
Open Date:May 7,2014-Close Date:Jun 6,2014
Page 3 of 4
CONTACT US
0 Web Mobile ® Phone Inquiry A1111ft Moil Payments
Access your Manage your 1-800-DISCOVER Discover Discover
account securely account anytime, (1-800-347-2683) PO Box 30943 PO Box 6103
j at Discover.com anywhere at TDD 1-800-347-7449 Solt Lake City Carol Stream
m.Discover.com UT 84130 IL 60197-6103
Transactions
Trans.Date Post Date
Fees Jun 2 Jun 2 LATE FEE $ 35.00
TOTAL FEES FOR THIS PERIOD 35.00
Interest Charged INTEREST CHARGE ON PURCHASES $ 156.89
INTEREST CHARGE ON CASH ADVANCES 0.00
INTEREST CHARGE ON BALANCE TRANSFERS 0.00
TOTAL INTEREST FOR THIS PERIOD 156.89
2014 Totals Year-to-date
TOTAL FEES CHARGED IN 2014 $ 210.00
TOTAL INTEREST CHARGED IN 2014 $ 883.48
_..._.......---..._...........__......._...._..—._.—......_._._........__..............__.........._......_....._........._............__........__............_............---...__.....---............._..................--.....—_....._........_._........._......_-......._....................__...—........_........_._..............
_ — -
Interest Charge Calculation
Your Annuol Percentage Rate(APR)is the annual interest rate on your account.
Current Billing Period:31 days
ANNUAL PERCENTAGE RATE BALANCE SUBJECT TO
TYPE OF BALANCE (APR) INTEREST RATE INTEREST CHARGE
Purchases 16.49% V $11,202.69 $156.89
Cash Advances 20.99% $0.00 $0.00
V=Variable Rate
Information For You
For more information about how interest charges are calculated see your Cardmember Agreement or go to www.discover.com/interestcharges
FICOO Credit Score Terms
The FICO®Credit Score we provide will never impact your credit score.
Your FICO®Credit Score is based on data from TransUnion and may be different from other credit scores.This information is intended for and delivered to
the Primary cardmembers only that have an available score and is available on the statement for individual accounts and on Discover.com for individual and
joint accounts.Discover and other lenders may use different inputs like a FICOO Credit Score,other credit scores and more information in credit decisions.
If you prefer not to receive your FICOO Credit Score on your statement,just call us at 1-800-DISCOVER(1-800-347-2683).Please give us two billing cycles
to process your request.To learn more,visit Discover.com.This benefit may change or end in the future.
FICO is a registered trademark of the Fair Isaac Corporation in the United States and other countries.
Cash,Cashier's Check,and Money Order Payments Toward Your Discover Account Discontinued at Searse
Effective July 1,2014,Discover cardmembers will no longer be able to make payments to their Discover account with cash,cashier's checks or money orders
at Sears locations.Cardmembers may still make payments towards their Discover account via personal check at Sears locations,online at www.discover.com,
by mailing us a personal check,cashier's check or money order,calling us at 1-800-DISCOVER(1-800-347-2683),or by sending us a cash payment from
any Western Union location.Please note,additional fees may be charged by Western Union or the business issuing your money order or cashier's check.
30368146
NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION
ELIZABE-TH'ROEDER• Account number endin0 in 0920 Open Date:May 7,2014-Close Date:Jun 6,2014 Page 4 of 4
—....._ __..... ... .....-- . _. 9.....__...........
30368146
_ VERIFICATION
i I � �M&W ell
koy e---,
(Name `s
(Title)
of DB Servicing Corporation, servicing affiliate of Discover Bank 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. Additionally, he/she verifies that
Discover Bank, f/k/a Greenwood Trust Company, which is an FDIC-insured Delaware state bank, lacks
sufficient knowledge or information to verify this complaint. He/she verifies that he/she is authorized to
make this verification. As an employee of DB Servicing Corporation, he/she has sufficient knowledge
and information to make this verification, and consequently verifies that the facts set 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.
It is further stated that Discover Bank and DB Servicing Corporation extend 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, 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 /
(Signature) r� L�r7j ��
ELIZABETH ROEDER DB Servicing Corporation servicing affiliate
XXXXXXXXXXXX0 92 0 For Discover Bank
WWR# 30368146 C A Pit SJS
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny RAnderson
Sheriff Cli- l €i PRO rHo O M ;
2014OCT 2I P4 2:59
CUMBERLAND COUNTY
Jody S Smith
Chief Deputy
Richard W Stewart
Solicitor
bpry4:o
FKaFN:.iFF PENNSYLVANIA
Discover Bank
vs.
Elizabeth Roeder
Case Number
2014-5717
SHERIFF'S RETURN OF SERVICE
10/10/2014 02:55 PM - Deputy William Cline, being duly sworn according to law, served the requested Complaint &
Summons by handing a true copy to a person representing themselves to be Don Roeder, Father, who
accepted as "Adult Person in Charge" for Elizabeth Roeder at 16 Meadowood P ac South Middleton,
Boiling Springs, PA 17007.
WILLIAM CLINE, DEPUTY
SHERIFF COST: $34.78 SO ANSWERS,
October 15, 2014 RONNY R ANDERSON, SHERIFF
(lc) CountySuile Sherif!, Teleosofi, enc.
Elizabeth Roeder
16 MEADOWOOD PL
BOILING SPRINGS, PA 17007
(717)713-6230
DISCOVER BANK,
Plaintiff,
vs.
ELIZABETH ROEDER
Defendant.
IN l haUi r O COMMON PLEAS
CU
LI
D CQUJNTY,
PENNSYLVANIA
DOCKET NO.: 14-5717
ANSWER TO THE COMPLAINT
I, Elizabeth Roeder answer the Complaint as follows:
1. Defendant is unable to admit or deny paragraph 1 of the Complaint and therefore leaves Plaintiff to its
proofs.
2. Defendant is unable to admit or deny paragraph 2 of the Complaint and therefore leaves Plaintiff to its
proofs.
3. Defendant is unable to admit or deny paragraph 3 of the Complaint and therefore leaves Plaintiff to its
proofs.
4. Defendant admits the allegations contained in paragraph 4 of the Complaint.
5. Defendant is unable to admit or deny paragraph 5 of the Complaint and therefore leaves Plaintiff to its
proofs.
6. Defendant denies the allegations contained in paragraph 6 of the Complaint.
7. Defendant denies the allegations contained in paragraph 7 of the Complaint.
8. Defendant denies the allegations contained in paragraph 8 of the Complaint.
Defendant also asserts the AFFIRMATIVE DEFENSES:
1. Plaintiff is barred by the Statute of Limitations.
2. Plaintiff is barred by its breach of the covenant of good faith and fair dealing from proceeding in
this action against Defendant.
3. Defendant disputes the amount and validity of the claimed amounts of principal, prejudgment
interest, late charges and attorney fees.
4. Defendant requests verification of the alleged debt.
5. Statute of Frauds.
6. Any contract requires the parties to submit to arbitration.
7. Any alleged debt has been securitized and therefore Plaintiff does not have standing.
WHEREFORE, Defendant requests that Plaintiff takes nothing against Defendant and that judgment
in favor of Defendant be entered; and, that Defendant be awarded all the costs of suit.
Res s Submitted,
Eliz th Roeder
16 i OWOOD PL
BOI . ' G SPRINGS, PA 17007
(717)713-6230
Defendant
CERTIFICATE OF SERVICE
The undersigned does hereby certify that a true and accurate copy of the foregoing was served by
fax or by U.S. Mail on October 30, 2014 to the following:
Wellman, Weinburg & Reis Co., L.P.A.
436 Seventh Avenue, Suite 1400
Pittsburgh, PA 15219
Eliza 4 a th Roeder
Defe ant
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff, No. 2014-05717
TYPE OF PLEADING:
vs. PLAINTIFF'S REPLY TO NEW MATTER
ELIZABETH ROEDER,
FILED ON BEHALF OF:
Defendant. Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William T. Molczan, Esquire
PA I.D. No. 47437
Weltman, Weinberg & Reis Co., L.P.A.
436 Seventh Avenue, Suite 2500
Pittsburgh, PA 15219
(412) 434-7955
WWR # 30368146
c -
;Nv
--i
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff,
vs.
ELIZABETH ROEDER,
Defendant.
No. 2014-05717
PLAINTIFF'S REPLY TO NEW MATTER
AND NOW, comes the Plaintiff, by and through its counsel, William T. Molczan, Esquire and
Weltman, Weinberg & Reis Co., L.PA., and files the following Reply to New Matter:
1. The averment contained in Paragraph 1 constitutes a conclusion of law to which no
response is required. By way of addition pleading, Defendant last made a payment on the account on
November 03, 2013.
2-7. The averments contained in Paragraphs 2 through 7 constitute conclusions of law to
which no response is required.
WHEREFORE, Plaintiff respectfully requests that this Honorable Court find in favor of the
Plaintiff and against the Defendant.
Respectfully Submitted:
WELTMAN, WEINBERG & REIS, CO., L.P.A.
By: (/ v� rL1,._
William T. Molczan squire
PA I.D.# 47437
436 Seventh Ave ' e, Suite 2500
Pittsburgh, PA 15219
(412) 434-7955
WWR# 30368146
CERTIFICATE OF SERVICE
I certify that I served a true and correct copy of Plaintiff's Reply to New Matter by First Class
Mail, Postage Pre -Paid, on the ( day of OZbi , 2014, upon the following:
Elizabeth Roeder
16 Meadowood Place
Boiling Springs, PA 17007
By: W
William T. Molczan,` 'squire
PA I.D.# 47437
436 Seventh Avenue, Suite 2500
Pittsburgh, PA 15219
(412) 434-7955