HomeMy WebLinkAbout05-3769
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
No: OS; - .J"Y&.9
CL~L ';'UL~
vs.
COMPLAINT IN CIVIL ACTION
KATHI L DARHOWER
AKA KATHI DARHOWER
Defendant
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
James C. Warmbrodt,42524
WELTMAN, WEINBERG & REIS CO., L.P.A.
436 Seventh Avenue, Suite 2718
Pittsburgh, PA 15219
(412) 434~7955
FAX: 412~338~7130
04354992 C A Pit KMJ
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
vs.
Civil Action No
KATHI L DARHOWER
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, is a corporation with offices at 3311 MILL MEADOW DR.
HILLIARD , OH 43026 .
2. Defendant is an adult individual(s) residing at the address listed
below:
KATHI L DARHOWER
3115 RITNER HWY
NEWVILLE, PA 17241
3. Defendant applied for and received a credit card issued by
Plaintiff bearing the account number 6011002584514400 , A copy of
Plaintiff's Statement of Account s attached hereto, marked as Exhibit
"A" and made a part hereof.
4. Defendant made use of said credit card and currently has a balance
due and owing to Plaintiff, as of July 13, 2005 , in the amount of
$5507.48 .
5. Defendant is in default by failing to make payments when due.
6. Plaintiff avers that the Agreement between the parties provides
that Defendant will pay Plaintiff's attorneys' fees.
7. Plaintiff avers that such attorneys' fees will amount to $1000.00
8. 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, KATHI L DARHOWER ,individually, in the amount of
$5507.48 with interest at the legal rate of 6.000% per annum from date
of judgment plus attorneys' fees of $1000.00 , and costs.
~
C. Warmbrodt,425 4
, WEINBERG & REIS CO., L.P.A.
4 6 eventh Avenue, Suite 2718
it sburgh, PA 15219
(4 2) 434~7955
F : 412~338~7130
~354992 C A Pit KMJ
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.
VERIFICATION
The undersigned does hereby verify subject to the penalties of 18 P A.C.S. 94904 relating to
unsworn falsifications to authorities, that he/she is Rohr>]"j- I\ctk i n<;
(Name)
Accounts Manager of Discover Financial Services Inc., servicing agent of the plaintiff herein, that
(Title) (Company)
he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint
in Complaint are true and correct to the best ofhislher knowledge, information and belief.
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(Signature)
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
No. 05-3769-CIVIL
vs.
PRAECIPE TO SETTLE, DISCONTINUE
AND END WITHOUT PREJUDICE TO REFILE
KA THI L DARHOWER - AKA
KATHI L DARHOWER
Defendant
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
JAMES C, WARMBRODT
PA LD #42524
WELTMAN, WEINBERG & REIS CO., L.P.A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, PA 15219
(412) 434-7955
VVWR#04354992
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SHERIFF'S RETURN ~ REGULAR
CASE NO: 2005~03769 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DISCOVER BANK
VS
DARHOWER KATHI L ET AL
SHANNON SUNDAY
, Sheriff or Deputy Sheriff of
Cumberland County, Pennsylvania, who being duly sworn according to law,
says, the within NOTICE
was served upon
DARHOWER KATHI L A/K/A KATHI DARHOWER
the
DEFENDANT
, at 0009:48 HOURS, on the 4th day of August
, 2005
at CUMBERLAND CO SHERIFF'S OFFICE 1 COURTHOUSE SQUARE
CARLISLE, PA 17013
by handing to
KATHI DARHOWER
a true and attested copy of NOTICE
together with
COMPLAINT
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing
Service
Affidavit
Surcharge
18.00
.00
.00
10.00
.00
28.00
So Answers:
~~~e
R. Thomas Kline
me
this
q
08/04/2005
WELTMAN, WEINBERG & REIS, CO.
By, ,ft(~he;&C~
Sworn and Subscribed to before
day of ~
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D2 =""'j A.D.
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Proth notary
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