HomeMy WebLinkAbout05-6160
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
No: 05- &.1'-.0
C'o;L~8L"'l
vs,
COMPLAINT IN CIVIL ACTION
ALEESHA ASPER
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
04641382 C A Pit WLG
.
IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
civil Action No tJJ: L/c,O
vs.
ALEESHA ASPER
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:
ALEESHA ASPER
24 W BIG SPRING AVE APT
NEWVILLE, PA 17241
3. Defendant applied for and received a credit card issued by
Plaintiff bearing the account number 6011002320373723 . 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 15, 2005 , in the amount of
$2044.04 .
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 $300.00 .
. 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, ALEESHA ASPER ,INDIVIDUALLY, in the amount of
$2044.04 with interest at the legal rate of 6.000% per annum from date
of judgment plus attorneys' fees of $300.00 , and costs.
This law firm is a debt collector a empting to collect this debt for
our client and any information obtained will be used for that purpose.
Warmbrodt,
, WEINBERG CO., L.P.A.
venth Avenue, Suite 2718
urgh, PA 15219
434-7955
AX 412-338-7130
04 41382 C A pit WLG
Verification
The undersigned does hereby verify subject to the penalties of 18 PAC.S. !l4904 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,
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Signature
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SHERIFF'S RETURN - NOT FOUND
CASE NO: 2005-06160 P
COMMONTWEALcH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
DISCOVER BANK
VS
ASPER ALEESHA
R. Thomas K'ine ,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
ASPER ALEESHA
but was
unable to locate Her in his bailiwick. He therefore returns the
COMPLAINT & NOTICE
, NOT FOUND , as to
the within named DEFENDANT
, ASPER ALEESHA
24 W BIG SPRING AVENUE
NEWVILLE, PA 17241
PER POST OFFICE, DEFENDANT'S ADDRESS IS
127 CUMBERLAND AVENUE SHIPPENSBURG, PA 17257. (FRANKLIN COUNTY)
Sheriff's Costs:
Docketing
Service
Not Found
Surcharge
So answers:
18.00
11.52
5.00
10.00
.00
44.52
..
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R. Thomas Kline
Sheriff of Cumberland County
WELTMAN WEINBERG REIS
12/20/2005
this
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IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY. PENNSYLV ANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
No.05-6160-C1VIL
vs.
PRAECIPE TO SETTLE. DISCONTINUE
AND END WITHOUT PREJUDICE TO REFILE
ALEESHA ASPER
Defendant
FILED ON BEHALF OF
Plaintiff
COUNSEL OF RECORD OF
THIS PARTY:
William 1', Molczan. Esquire
PA J.D. #47437
WELTMAN. WEINBERG & REIS CO.. I..P,A.
2718 Koppers Building
436 Seventh Avenue
Pittsburgh. P A 15219
(412) 434.7955
WWR#04641382
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IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYL VANIA
CIVIL DIVISION
DISCOVER BANK
Plaintiff
VS.
Civil Action No, 05-6l60-CIVIL
ALEESHA ASPER
Defendant
PRAECIPE TO SETTLE DISCONTINUE AND END
WITHOUT PREJUDICE TO REFILE
TO THE PROTHONOTARY OF COUNTY:
Settle, Diseontinue and End without Prejudiee to Refile the above-eaptioned matter upon the reeords of the
Court and mark the eosts paid,
WELTMAN. WEIN ERG & REIS CO" L.P,A.
By:
William' . Molczan, Es
PA l.D #47437
WELTMAN. WEINBERG & REIS CO" L.P.A,
2718 Koppers Building
436 Seventh Avenue
Pittsburgh, i' A 15219
(412) 434.7955
WWR#04641382
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