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Home My WebLink About05-5047 . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No : 0 S" - ~Ol.J 7 Ci u i L ~ 0Z-"1. vs. COMPLAINT IN CIVIL ACTION LISA M RHONE AKA LISA RHONE Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt,42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 323 W. Lakeside Ave 2nd Fl Cleveland, Oh 44113 (412) 434-7955 FAX: 412-338-7130 04469051 C A pit WLG . IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No OS'...)OY1 LISA M RHONE 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. YOJ 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 t OH 43026 . 2. Defendant is adult individual{s} residing at the address listed below: LISA M RHONE 957 RIDGE RD SHIPPENSBURG, PA 17257 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011002710298357 . 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 September 15, 2005 , in the amount of $8594.04 . 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, LISA M RHONE ,INDIVIDUALLY, in the amount of $8594.04 with interest at the legal rate of 6.000% per annum from date of judgment plus attorneys' fees of $1000.00 , and costs. ~~~ Jame~ . Warmbrodt,42524 WELT ,WEINBERG & REIS CO., L.P.A. 323 Lakeside Ave 2nd Fl Cl v, land, Oh 44113 ( ) 434-7955 : 412-338-7130 ~469051 C A Pit WLG 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. June 29, 2005 ... I 31 SDSN6A01 0009241 LISA RHONE 957 RIDGE RD SHIPPENSBURG PA 17257-9722 SAVE TODAY! Call 1-866-894.5727 to transfer your higher-rate balances to your Discover@) Card or visit Discovercard.com. I I, i"y .~ -r' , ,\ '-'! , ""'l 1..), ',J/ ,J ",/ PO BOX 15251 11I11I11"11I11.11I11.11111 WILMINGTON DE 19886-5251 4ddress or telephone change? Please print change in the space above, 1,"11I,1111'11.111111 1111I1,1'111.1,1,1'11111,1.11111111.1111 (l( go to Discovercard_com. 000006011002710298357000000000000000140800 Discover Platinum Card Account Summary Closing Date: May 31, 2005 page 1 of 2 previous balance $8,594.04 pccount number 6011 0027 1029 8357 payments and credits 8,594.04 payment due date June 29, 2005 purchases + 0.00 'minimum payment due $1,408.00 cash advances + 0.00 credit limit $7,500 credit available $0 balance transfers + 0.00 cash credit limit $3,800,00 FINANCE CHARGES + 0.00 ;ash credit available $0,00 new balance = $0.00 EXHIBIT t'A /I Cashback BonusQ!) Cashback Bonus@ Anniversary Date: September 17 Previous Cashback Bonus Award Balance Purchase Award This Period Cashback Bonus Award Total Redemptions This Period Cash back Bonus Award Balance Award Available to Redeem $ + 0.00 0.00 0.00 0.00 0.00 0.00 $ ;Transactions trans. post date date Payments and Credits May 31 May 31 INTERNAL CHARGE-OFF $ -8,594.04 Nominal ANNUAL Transaction Average Daily ANNUAL Periodic Fee Daily' Penodic PERCENTAGE PERCENTAGE FINANCE FINANCE Balances Rates RA TES RA rES CHARGES CHARGES - mrrent billing period: 14 days Purchases $0 0.04586% 16.74% V 16.74% $0 none Gash Advances $0 0.05956% 21.74% V 21.74% $0 $0 - TI1~Jates that apply to your Account are either fixed (F) or they may vary (V) as noted above. Veriflcation The undersigned does hereby verify subject to the penalties of 18 PAC,S. ~4904 relating To unsworn falsifications to authorities, that he/she is Robert Adkins Accounts Manger of Discover Bank, Plaintiff herein, that he/she is duly authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and correct to the best of his/her knowledge, information and belief. ~.~ WWR# OLfL/(,qo) I G ~ ~ 7J U{ ~ t ~ r<) 0 0 c=..:> c:: c:? -1'1 ,"-,oF' :r." U( ;::"'" (,') PI n1c;::, ~ () -\) - N ::g\:':j ~ w r 0" ;:5,/., ~ 10 -U ~':' :::%, ~ C)?) .-'_...~ (~llrn -.a <f1 C;? ~ " t en ~ -.c:::. m ~ - -- ...............----.. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff NO.05-5047CIVIL vs. PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE LISA M RHONE Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C. WARMBRODT PA 1.0 #42524 WELTMAN, WEINBERG & REIS CO., L.PA 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04469051 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No 05-5047CIVIL LISA M RHONE Defendant PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR Settle, Discontinue and End the above-captioned matter upon the records of the Court without prejudice to refile and mark the costs paid. WELTMAN, WEINBERG & REIS CO., L.PA SWORN TO AN:rLSU SCRIBED before me this r-- day '{"''', '. ( of , 2005 l-- Noia"",""'" \' Wendy L. Gault No\arj Poi,;,c CiIy Of Pittsburgh, AllogllellY CO:;'.~I! . My Com",","!O" l'ixpires July 1b, 6UOO \ 1\____ ~~...~;;~O'~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 05-5047CIVIL vs PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE LISA M RHONE Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C WARM BRODT PA 1.0 #42524 WELTMAN, WEINBERG & REIS CO., L.P.A 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04469051 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 05.5047CIVIL LISA M RHONE Defendant PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR: Settle, Discontinue and End the above-captioned matter upon the records of the Court without prejudice to refile and mark the costs paid. WELTMAN, WEINBERG & REIS CO., L.P.A. SWORN TO A~)UrSCRIBED before me this ~ day i" ' of ,~OO, NaTAR L1C Notanai;;'l;lc. I Wendy L Gault. NOla"; Pub!>c C!;' Of Pittsburgh, Ailegheny CO"",> ' MyC"",..1SSi0l'\~JllIy15,~O(' J 1\......... P""A~iiJij;.~"ii:f<.C;:~rt~r r-> c.::? ~ -" f:5~ .... \ r-.:> q, .-\ 1: -r. '"'r\-" ''OJ ~Jo );~_~~)l ()t) ~S~) \' n >.;.\ ~,. ~~'1 -0 :;'t: 1"-' .. <f' v"'j