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Home My WebLink About05-5698IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No DANA B CARVER 65 J?4(1 l rr?i.l . ??/LrYI 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 adult individual(s) residing at the address listed below: DANA B CARVER 435 GETTYSBURG PIKE MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011002770292605 . 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 October 24, 2005 , in the amount of $9005.69 . 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 $1500.00 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 , DANA B CARVER INDIVIDUALLY , in the amount of $9005.69 with interest at the legal rate of 6.0001 per annum from date of judgment plus attorneys' fees of $1500.00 , and costs. James Warmbrodt,42 24 WELT WEINBER(, & REIS CO., L.P.A. 436 e enth Avenue, Suite 2718 Pi sbu gh, PA 15219 ( 2) 34-7955 F : 4 2-338-7130 04542 27 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. Verification The undersigned does hereby verify subject to the penalties of 18 PA.C.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. Signature WWR#`l? N ?l?,T I .: t ? °?sl tfi '"? < i V7 -i N `< I `J U 'F-? ?? SHERIFF'S RETURN - REGULAR CASE NO: 2005-05698 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS CARVER DANA B AKA DANA CARVER DOUGLAS RUZANSKI , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CARVER DANA 3 AKA DANA CARVER the DEFENDANT , at 2048:00 HOURS, on the 9th day of November , 2005 at 435 GETTYSBURG PIKE MECHANICSBURG, PA 17055 by handing to DANA CARVER 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 10.56 Postage .37 Surcharge 10.00 nn So Answers: l% R. Thomas Kline 38.93 11/14/20 WELTMAN Sworn and Subscribed to before me this If}? day of A.D. Protho ary By: IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. DANABCARVER - AKA DANA CARVER Defendant No. 05-5698-CIVIL PRAECIPE TO SETTLE, DISCONTINUE & END WITH PREJUDICE, FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA ED #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04542427 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. DANA B CARVER - AKA DANA CARVER Defendant Civil Action No. 05-5698-CIVIL PRAECIPF. TO SETTLE DISCONTINUE AND END WITH PREJUDICE TO THE PROTHONOTARY OF COUNTY: Please kindly Settle Discontinue and End the above captioned matter with Prejudice upon the records of the Court and mark the cost paid. Sworn to and sub Before me the _ Dav of JanuaRY, Y WELTMAN, WEINBERG & REIS CO., L.P.A. ?v James C. rmbrodt By. PA LD #x`425 4 WELTMA , WEINBERG & REIS CO., L.P.A. 27181op ers Building 436j evirth Avenue PitI ftorgh, PA 15219 (4y2) 434-7955 W &R404542427 Had J. Kelly, Notary Public Of Pittsburgh, Allegheny County ornrnission Expires Nov. 4, 2009 Pennsylvania Association of Note r> ? ? ?? ? 1 ? 1 - `l i Christopher E. Rice Attorney I.D. No. 90916 MARTSON DEARDORFF WILLIAMS & OTTO Ten East High Street Carlisle, PA 17013 (717) 243-3341 C 2010 JAN _6 PM 2% p8 11 Attorneys for Plaintiff Cumb n'? fYIV 'tJ Y MOUNTZ JEWELERS, L.P. : IN THE COURT OF COMMON PLEAS OF Plaintiff : CUMBERLAND COUNTY, PENNSYLVANIA DAVID THOMAS, V. Defendant NO. 06 - 5698 CIVIL TERM PRAECIPE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please mark the judgment in the above-referenced matter satisfied and the action discontinued. MARTSON LAW OFFICES By. (2-4 4a S x,--- Christopher E. Rice, Esquire I.D. Number 90916 Ten East High Street Carlisle, PA 17013 (717) 243-3341 Date: /_/ -/0 Attorneys for Plaintiff CERTIFICATE OF SERVICE I, Mary M. Price, an authorized agent of MARTSON DEARDORFF WILLIAMS OTTO GILROY & FALLER hereby certify that a copy of the foregoing Praecipe was served this date by depositing same in the Post Office at Carlisle, PA, first class mail, postage prepaid, addressed as follows: Mr. David Thomas 100 Walnut Street Lemoyne, PA 17043 MARTSON LAW OFFICES By %-A,- 2 V? - 0-- Mjryj4. Price Ten 15ast High Street Carlisle, PA 17013 (717) 243-3341 Dated: ?/(? / /d This is a debt collecting firm attempting to collect a debt. Any information obtained will be used for that purpose.