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Home My WebLink About06-0372 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: l:>b - 31~ Ct~L~EiL~ vs. COMPLAINT IN CIVIL ACTION CRYSTAL LYNN MOULFAIR 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 04486616 C A Pit WLG IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff Civil Action No Ofc,-31~ C.i(J.L'--r~ vs. CRYSTAL LYNN MOULFAIR 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: CRYSTAL LYNN MOULFAIR 167 ASHFORD DR ENOLA, PA 17025 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011002030748305 . 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 December 29, 2005 , in the amount of $2232.66 . 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, CRYSTAL LYNN MOULFAIR ,INDIVIDUALLY, in the amount of $2232.66 with interest at the legal rate of 6.000% per annum from date of judgment plus attorneys' fees of $300.00 and costs. L.P.A. 2718 This law firm is a debt collector at empting to collect this debt for our client and any information obtained will be used for that purpose. 03 SDSN6A01 0001408 CRYSTAL LYNN MOULFAIR 102 RACE ST MILLERSBURG PA 17061-1630 ,..-J'"-''' --- -_.- ;J>L- Please make check payable to Discover Card. You are overfimit. Pay tM sum of the monthly minimum payment plus the overfimit amount of $609. 70. June 2, 2004 To order Cash Access Checks, select your P.I.N., or to find cash locations caU 1-800-DISCOVER (1-800-347-2683) or visit Discovercard.com. PO BOX 15251 11I",11",11"",11.1",11 WILMINGTON DE 19886-5251 1",111,1,.1,.1,1"1.,11",1,/",1,1,1.1""11,1,1,,,,111.1,,1 Address or telephone change? Please print change in the space above, or gO to Discovercard.com. 000006011002030748305026097000000000034100 Discover Card Account Summary account number payment due date minimum payment due credit limit credit available cash credit limit cash credit available 6011 002030748305 June 2, 2004 $341.00 $2.000.00 $-609.00 $1,000.00 $0.00 -- Closing Date: May 3, 2004 page 1 of 2 previous balance payments and credits purchases cash advances balance transfers $2,488.08 0.00 + 70.00 + 0.00 + 0.00 + 51.62 = $2,609.70 FINANCE CHARGES new balance You may be able to avoid Periodic Finance Charges, see the reverse side for details. Cash back BonusOll Cashback BonuS@Anniversary Date: April 3 Opening Cashback Bonus Balance New Cashback Bonus Earned $ + 0.00 0.00 0.00 0.00 Cashback Bonus Balance Available to Redeem $ $ Transactions trans. post date date previous statement balances tran date May 3 May 3 post date May 3 May 3 FINANCE CHARGES: OLD BALANCE FINANCE CHARGES: CASH FINANCE CHARGES: PURCHASES FINANCE CHARGES: BALANCE TRANSFERS PRINCIPAL: OLD BALANCE PRINCIPAL: CASH PRINCIPAL: PURCHASES PRINCIPAL: BALANCE TRANSFERS $ 0.00 0.00 0.00 0.00 0.00 0;00 0.00 0.00 EXHIBIT I; 35.00 35.00 OVERLlMIT FEE lATE FEE Please note, the Traditional Cashback Bonus award is now called the Purchase Cashback Bonus award. " . . 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, information and belief. ~(dk~k:7 Signature WWR# fJ G/ I..{ 'i;GJ ([){ (0 G -k::1.. G 1f If\ ~ if\ if\ - ~ \) ~ w , -0 C) r ?=- " ....4 ~ Lv (... . -: -, ~ C ;('. r ~ . - ~ -- +- \...:.: *~ . - ~ ( ."'... 1....) (, ~ I/" tI\ 0 ~ SHERIFF'S RETU~N - NOT FOUND CASE NO: 2006-00372 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DISCOVER BANK VS MOULFAIR CRYSTAL LYNN 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 MOULFAIR CRYSTAL LYNN but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , MOULFAIR CRYSTAL LYNN 167 ASHFORD DRIVE ENOLA, PA 17025 PER POST OFFICE, DEFT'S ADDRESS IS 602 LANSVALE ST MARYSVILLE, PA 17053-1144. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 13.20 5.00 10.00 .00 46.20 /- So an.swe~. . ~~... ....../'_/~ ~// / ------~ -.-----'<7""~~ R. Thomas Kllne Sheriff of Cumberland County WELTMAN WEINBERG REIS 01/26/2006 Sworn and subscribed to before me this 10~ day of (}~I "W~ Pr thono k 'I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. 06-372 CIVIL TERM vs. PRAECIPE TO SETTLE. DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE CRYSTAL LYNN MOULFAIR Defendants FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt P A l.D #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh A venue Pittsburgh. P A 15219 (412) 434-7955 WWR#04486616 I ... IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY. PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 06-372 CIVIL TERM CRYSTAL LYNN MOULFAIR Defendants PRAECIPE TO SETTLE. DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR: Kindly settle. discontinue and end without prejudice to refile the above-captioned matter upon the records of the Court and mark the costs paid. WELTMAN, WEINBERG & REIS CO.. L.P.A. By: Jan PA I.D #4252 WELTMAN WINBERG & REIS CO.. L.P.A. 2718 Kopp' rs uilding 436 Seve h venue Pittsbur . A 15219 (412) 434-7955 SWORN TO AND SUBSCRIBED \S" \ day , '. --'-, LI. , ') COMMONWEALTH OF PEt'':l2.YLVANIA Notarial S~\;;' Heidi J. Kelly, Notary iJJblic City Of Pittsburgh, Meqheny County My Commission Exp11e<> Nov. 4. 2009 Member. Pennsylvania As"Qciation oi NotarIes (