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Home My WebLink About05-6070 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: OS - (p0'70 c;o;(-r~ vs. COMPLAINT IN CIVIL ACTION LEANDER A LEDEBOHM AKA LEANDER LEDEBOHM 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: 4l2-338-7l30 04642105 C A pit WLG IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff Civil Action No o5'~ t.rJ7o ~ Ie,.- vs. LEANDER A LEDEBOHM AKA LEANDER LEDEBOHM 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) 249-3l66 COMPLAINT l. Plaintiff, is a corporation with offices at 33ll MILL MEADOW DR. HILLIARD , OH 43026 . 2. Defendant is adult individual{s) residing at the address listed below: LEANDER A LEDEBOHM 5214 DEERFIELD AVE MECHANICSBURG, PA l7050 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 60l129865088l869 . 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 November 10, 2005 , in the amount of $lOl42.97 . 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, LEANDER A LEDEBOHM ,INDIVIDUALLY, in the amount of $lOl42.97 with interest at the legal rate of 6.000% per annum from date of judgment plus attorneys' fees of . Warmbrodt,42524 , WEINBERG & REIS CO., L.P.A. eventh Avenue, Suite 2718 p.t sburgh, PA l52l9 4 2) 434-7955 X: 412-338-7130 04642105 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. LlI, 'v J:/'t ;D $10,142.97 $2,076.00 enter amount enclosed below payment due date September 21, 2005 $1 ./ 22 SDSN6A01 0008228 LEANDER LEDEBOHM 5214 DEERFIELD AVE MECHANICSBURG PA 17050-6824 Consolidate bills quickly and securely with a Balance Transfer to your Discover Card. Call 1-877-353-0986 TODAY I Address or telephone change? Please print change in the space above, or go to DiscovefCard.com, PO BOX 15251 11I",11"",1,1,,1.1.11,,1 WILMINGTON DE 19886-5251 1",111,1"1,.1.1"1"11",1,1,,,1,1,1,1,,,,11,\,1,,,,11I,1"I 000006011298650881869101429700000000207600 - Discover Platinum Card Account Summary Closing Date: August 22, 2005 page 1 of 1 account number payment due date minimum payment due credit limit credit available cash credit Jimit cash credit available 6011 29865088 1869 Sep1ember 21, 2005 $2,076.00 $8,300 $0 $4,300.00 $0.00 previous balance payments and credits purchases cash advances balance transfers FINANCE CHARGES new balance + + + + $10,170.47 27.50 0.00 0.00 0.00 0.00 $10,142.97 Cash back Bonus" Cashback BonuS@ Anniversary Date: February 22 Previous Cashback Bonus Award Balance Purchase Award This Period Cashback Bonus Award Total Redemptions This Period $ + 0.00 000 0.00 0.00 0.00 0.00 Cashback Bonus Award Balance Award Available to Redeem $ Transactions trans. post date date Payments and Credits Aug 11 Aug 12 COL'HOUSE VIDEO CLUBA~2-2001 IN 50217169080 CJ\HIB T $ .27.50 J.18IHX3 Nominal ANNUAL Transaction Average Daily ANNUAL Periodic Fee Daily Pet/odic PERCENTAGE PERCENTAGE FINANCE FINANCE Balances Aates RATES RATES CHARGES CHARGES current billing period: 22 days Purchases $0 0.07121% 25.99% V 25.99% $0 none Cash Advances $0 0.07121% 25.99% V 25.99% $0 $0 previous billing period: 11 days Purchases $0 0.07121% 25.99% V 25,99% $0 none The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above, Questions? Call1-800-DISCOVER (1-800-347-2683) or log on to Discovercard.com. For TOO (Telecommunication Device for the Deaf) assistance, see reverse side, Send billing error nolice to: Discover Plalinum; P,O. Box 15192; Wilmington, DE 19850-5192, Verification The undersigned does hereby verify subject to the penalties of 18 PA.C.S. S4904 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, infonnation and belief. ~/u;t~ Signature WWR# (jL)l Qllli()S ~ ~ -,:J V{ ~ \L ~ B t/1 - ~ -:t ~ - w r -!:" ~ C> D ( - -+- .~ Q ~' C), c:' ".._\, ( --', ; ,'~ -; -."",' '[',,,j CJ \-,', -.-. ( ." ~..... SHERIFF'S RETURN - REGULAR CASE NO: 2005-06070 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS LEDEBOHM LEANDER A ET AL DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LEDEBOHM LEANDER A AKA LEANDER LEDEBOHM the DEFENDANT at 1929:00 HOURS, on the 19th day of December, 2005 at 103 N SPORTING HILL ROAD MECHANICSBURG, PA 17050 by handing to LEANDER E LEDEBOHM, FATHER 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 Service Affidavit Surcharge So Answers: 18.00 11.52 .00 10.00 .00 39.52 ;;~~~~;f:.~;;~;'::" "- ' //~ ,('lV /;" ~ . /1 ,_e..<.....~ R. Thomas Kline 12/20/2005 WELTMAN WEINBERG REIS Sworn and Subscribed to before By: [/d~[^T ' Deputy S eriff / me this II ~ day of q'?!24ftl1i~ . Prot . no!; ry A.D. .... IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYL VANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 05-6070 CIVIL TERM VS. PRAECIPE FOR DEFAULT JUDGMENT LEANDER LEDEBOHM AKA LEANDER LEDEBOHM Delendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: W]LLIAM T. MOLCZAN, ESQUIRE PA !.D.#47437 Weltman, Weinberg & Reis Co.. L.P.A. 27] 8 Koppers Bldg. 436 Seventh Avenue Pittsburgh. P A 15219 (4]2) 434-7955 WWR#04642I 05 Judgment Amount S 11.642.97 THIS LA W FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. . .", IN THE COURT OF COMMON PLEAS CUMBf:RLAND COUNTY. PENNSYl.V ANIA CIVIL DIVISION DISCOVER BANK Plaintitf vs. Civil Action No. 05-6070 CIVIL TERM LEANDER LEDEBOHM AKA LEANDER LEDEBOHM Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROIHONOT ARY: Kindly enter Judgment against the Defendant. LEANDER LEDEBOHM AKA LEANDER LEDEBOHM above named. in the default of an Answer" in the amount of $11.642.97 computed as follows: Amount claimed in Complaint $10142.97 Interest from date of judgment at the legal interest rate of 6% per annum Attorney's fees $1500.00 TOTAL $11.64297 I hereby certify that appropriate Notices of Default. as attached have been mailed in accordance with PA R.C.I'. 237.1 on the dates indicated on the Notices. WELlMAN, WEINBERG & REJS CO, L.PA ByUjt~~....~ WILLIAM T. MOLCZA ESQUIRE PA LD.#47437 Weltman. Weinberg & Reis Co.. L.P.A. 2718 Knppers Bldg. 436 Seventh Avenue Pittsburgh, P A 15219 (412) 434-7955 WWR#04642/05 Plaintiffs address is: cio Weltman, Weinberg & Rcis Co., L.P.A., 2718 Koppers Building, 436 71h Avenue. Pittsburgh, P^ 15219 And that the last known address of the Delendam is: 5214 DEERFIELD AVE, MECIIANICSBLlRGYA 170 '" IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff Case # h')-CoO''(O'()J\\ LEANDER A LEDEBOHM Defendant(s) IMPORTANT NOTICE TO: LEANDER A LEDEBOHM 5214 DEERFIELD AVE MECHANICSBURG,PA 17050 Date of Notice: 1~-L3-0c..p WWR#: 04642105 YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE .A LAWYER, GO TO OR TELEPHONE THE FOLLOWING OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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 - /. / BY: JAMES BRODT, PA I. #42524 WELT ,WEINBERG & REIS CO., L.P.A. 2718/ OPPERS BLDG, 436 7TH AVE. , pI'J;rSBURGH, PA 15219 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYL VANIA CIVIL DIVISION DISCOVER BANK Case no: 05-6070 CIVIL TERM Plaintill NON-MILITARY AFFIDAVIT Ys. LEANDER LEDEBOHM AKA LEANDER LEDEBOHM Defendant The undersigned. who first being duly sworn. according to law, deposes and slates as f()lIows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Afliant further states that the within Amdavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 Us.e. App. Ii 521. Afliant further states that based upon investigation it is the aman!'s belief that the Defendant. LEANDER LEDEBOIIM AKA LEANDER LEDEBOHM is not in the military service. AfIlant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the Defendant, LEANDER LEDEBOHM AKA LEANDER LEDEBOHM is not in the military service. F1\I1her Affiant sayeth naught. Jd1!:~1i!/ ~ AFFIANT "'-y--=- SWO N TO AND SUBSCRIBED in my presence this Y _ day of ."2 wz?; <C ,L__.... NOTARY pul3t:rC ./ This law firm is a debt collector attempting to collect this debt for our client and any inf'lrl11at;on obtained will be used for that purpose. Request for Military Status Page] of] .~ Department of Defcnse Manpower Data Center F1:B-06-200613:13:33 Military Status Report Pursuant to the Service Members' Civil Relief Aet ... Last Name First/Middlc Bcgin Date I Activc Duty Status I Scrvice/Agcncy LEDEBOHM LEANDER A Based on the information you have furnished, the DMDC does not possess any information indicating that thc individual is currently on aetive duty. Upon searching thc information data banks ofthc Departmcnt of Dcfense Manpower Data Center, the abovc is the current status of the individual, per the Information provided, as to all branches ofthe Military. "F~)~kk ;, (J ./ . I:'.;r, 6-_ J_PVA,"- Robert J. Brandewic, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, V A 22209-2593 The Defcnse Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defensc Enrollment and Eligibility Reporting Systcm (DEERS) databasc which is thc official source of data on eligibility for military mcdical care and other eligibility systcms. Thc Department of Defense strongly supports the enforccment of the Scrvice Members Civil Relief Act [50 uses Appx. 99 501 et scq] (SeRA) (formerly the Soldiers' and Sailors' Civil Rclief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error ratc. In the event the individual referenced above, or any family member, fricnd, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are most strongly encouragcd to contact us by phone at (703-696-6762). Wc will thcn conduct further research. Your failure to re-contact DMDC may cause provisions of the SCRA to bc invokcd against you. This responsc reflccts currcnt active duty status only. For historical information, plcasc contact the military scrvices SCRA point of contact. Sec: hUp ://WINW .dc lense link.m i IIfaq/pis/PC09SL DR .htm I. WARNING: This certificate was providcd based on a name and Social Security numbcr (SSN) provided by the requester. Providing an erroneous name or SSN will causc an crroncous ecrtificatc to be provided. Report If):BQTYCIIOYQRV https :/Iwww.dmde.osd.mil/scra/ owa/scra. prc.. Select 2/6/2006 ~ ~ t~ \ B -, "\::) ~ ~ ~ -u " .t: V\ ~ ..c:: 't--> \ ~ ~ -= :tJ ~, C> +- 2=- r r-" ".,). C) ';:,:; ~(l C_~: ,\' .---1 ~\ .'i~, jt, :;\ ~j --,-1 -~.~ 0> -'t'" -,", r<) CG IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 05,6Cl70 CIVIL TERM LEANDER LEDEBOHM AKA LEANDER LEDEBOHM Defendant NOTICE OF JUDGMENT OR ORDER TO: () Plaintiff (xx) Defendant ( ) Garnishee Y OLl are hereby notitied that the following ()r~ Judgment "vas entered against you on_ T'E.bJ l.., .;) D~ (xx) Assumpsit Judgment in the amount 01'$11,642.97 plus costs. () Trespass Judgment in the amount of$__ plus costs. () Ifnot satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau ofTraftic Safety, Harrisburg, PA. (xx) Entry of Judgmenl of () Court Order () Non-Pros () Cont'ession (xx) Det"ult () Verdict () Arb itration A\vard LEANDER A LEDEHOHM - 5214DEERFIELDAVE MECHANICSBURG,PA 170 Prothonotary , l /) By . 01~-i;;vL~ PRrif:LwT ARY {OR DEFt TYT if- ~ Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A.. 2718 Koppers Building, 436 ih Avenue. Pittsburgh, PA 15219 1-888-434-0085