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Home My WebLink About05-5735 i IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff I Ci vil Action No OS- - '1:7 d5 (!t u~C-T€fl.>>t vs. KRISTIE GREY 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. HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE FORTH BELOW TO FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU DO NOT THE OFFICE SET 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: KRISTIE GREY 3 HARVARD PL APT B CAMP HILL, PA 17011 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011002410698690 . 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 25, 2005 , in the amount of $2875.84 . 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 $500.00 . , 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, KRISTIE GREY ,INDIVIDUALLY, in the amount of $2875.84 with interest at the legal rate of 6.000% per annum from date of judgment plus attorneys' fees of $500.00 , and costs. 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. /"..._~ L.P.A. 2718 \ Verification The undersigned does hereby verify subject to the penalties of 18 P A.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. ~w~ Signature WWR# li11 d-11W rC1 . c.l P \.) -k). 7' l.f1 ~ ~ ~ Cl .-> q, c:"':c> C c."" <J"' -' - r(3 tJ( .-J \ ,~ "". ::r:""'t'\ - ~ j--"; C> p'lp \) .."...- ..r ~ ;nr:::- \ :/37-, C>- ~ c.,) \.J) t ~~) :'1; -0 <,---('\ ~ ()-~< ::'- .1"'.,.(') '-!: (~~:)fn :C\ ~ ? <.Jl :~ c.,) ;- - SHERIFF'S RETURN - NOT FOUND ~ CASE NO: 2005-05735 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DISCOVER BANK VS GREY KRISTIE R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT GREY KRISTIE but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , GREY KRISTIE 3 HARVARD PL APT B CAMP HILL, PA 17011 DEFENDANT NOT A GIVEN ADDRESS. THERE IS AN EVICTION NOTICE ON THE DOOR. Sheriff's Costs: Docketing Service Not Found Surcharge Postage 18.00 14.40 5.00 10.00 .37 47.77 So answers ~~_<<-:;:..:-~:~::~ .... / .~~~ R. Thomas Kline Sheriff of Cumberland County WELTMAN WEINBERG REIS 11/30/2005 Sworn and subscribed to before me this {"IS day of A.Dw....,k dlJ05 ~A.D. c1( --- prothonGt r . " IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 05-5735 CIVIL TERM vs PRAECIPE TO REINSTATE COMPLAINT KRISTIE GREY Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY James C. Warm brodt, 42524 WELTMAN, WEINBERG & REIS CO, LPA 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (421) 434-7955 FAX 412-338-7130 WWR#04641409 ", IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 05-5735 CIVIL TERM KRISTIE GREY Defendant PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO, LPA c:: ~-)U/~v/ . By: James C. Warm brodt, 42524 WELTMAN, EINBERG & REIS CO, LPA , 436 Sev~t Avenue, Suite 2718 Pittsbur~h, A 15219 (421) -4P4 955 i AX 412-338-7130 l-~; (-"- :..":? c-.':.l ~.~\ c:.r'" ~, "-", :;;.", .-----.~ ~fl f'" 0) ~ ",~'( t':-? f" 1'-' SHERIFF'S RETURN - NOT FOUND CASE NO: 2005-05735 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND Dr SCOVER BANK VS GREY KRISTIE R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT GREY KRISTIE but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , GREY KRISTIE 3 HARVARD PL APT B CAMP HILL, PA 17011 DEFENDANT MOVED TO MARYLAND APPROXIMATELY THREE YEARS AGO. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 4.40 5.00 10.00 .00 37.40 R. Thomas Kline of Cumberland County WELTMAN WEINBERG REIS 04/03/2006 Sworn and subscribed to before me this /( ---t?.. day of . ~{)O~'2~u prh~ ~ , .. '" IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. : 05-5735-CIVIL vs. PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE KRISTIE GREY Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C. WARMBRODT PA I.D #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04641409 \, " IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. : 05-5735-CIVIL KRISTIE GREY 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. ,_ ,...., '"u---:::'> SWORN TO AND SUBSCRIBED before me this ~~ay '/ ,2007 COMMONWEALTH OF Nl. NotarIal Seal Wayne A. Jones. Notary Public City Of Pitlsburgl, Allegheny CountY MyComnission ExplresJune 29, 2010 Member, Penns~lvania Association of Notarie& C) c 'ui'":: ,-n f~; -"";'" ..~ ,....., = = ....... <'- J> Z o "11 -l :J:'"1'l fl1p -om :8 S? ~~1c...) >5 :lj 0'7 C) om ---l ?O -< N \.0 -0 3: .r- r\..)