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Home My WebLink About06-0498 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. SHARILYN BONURA Defendant No: l._. ?? iL>I'C l`1-11 COMPLAINT IN CIVIL ACTION 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 04908412 C A Pit WLG IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. SHARILYN BONURA Defendant Civil Action No 01?-•yQOP e;ut"L"- 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: SHARILYN BONURA 3904 PARK CIR CAMP HILL, PA 17011 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011002340222900 . 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 January 16, 2006 , in the amount of $11593.36 . 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 , SHARILYN BONURA INDIVIDUALLY , in the amount of $11593.36 with interest at the legal rate of 6.000°1 per annum from date of judgment plus attorneys' fees of $1500.00 , and costs. BERG & REIS CO., L.P.A. reventh brodt, venue, Suite 2718 A 15219 5 7130 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. Law Offices of Weltman, Weinberg & Reis Co., L.P.A. 436 Seventh Avenue, Suite 2718 Pittsburgh, PA 15219 (412) 434-7955 January 16, 2006 Office of the Prothonotary CUMBERLAND County Courthouse ONE COURTHOUSE SQUARE CARLISLE, PA 17013 Dear Sir or Madam: Enclosed please find Plaintiff's Complaint in Civil Action which we wish to file with the Prothonotary of your county. Please process pursuant to normal procedures and return time-stamped copies of the face sheet to the undersigned in the envelope provided. Thank you for your attention to this matter. Very truly yours, Kasey Stack Enclosures 04908412 C A Pit WLG VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S Section 4904 relating to unsworn falsifications to authorities, that he/she is - of Title) (Company) 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. re) 04908412 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. Section 4904 relating to unsworn falsification to authorities, he/she is an attorney for the Plaintiff herein; makes this Verification based upon the facts as supplied to her by the Plaintiff and/or its agents and because the Plaintiff is outside the jurisdiction of the court and the Plaintiff's Verification cannot be obtained within the time allowed for filing of this pleading, and that the facts set forth in the foregoing pleading are true and correct to the best of her knowledge, information and belief. 04908412 C A Pit WLG ..??- n a, Vil-YLYi Address or telephone change? Please print change in the space above, or go to Discovercard.com. visit ulscovercard.com. PO BOX 15251 111ot16td{tr1111Il u? WILMINGTON DE 19886-5251 1111111th,1t,1t[loll iiutiiir,ddtitinuiiritiuuiiitI III 000006011002340222900115933600000000079100 Discover Platinum Card Account Summary Closing Date: November 4, 2005 page 1 of 1 account number payment due date minimum payment due credit limit credit available cash credit limit cash credit available 6011 0023 4022 2900 December 3, 2005 $791.00 $11,000.00 $0.00 $5,500.00 $0.00 previous balance $11,260.79 payments and credits - 0.00 purchases + 74.00 cash advances + 0.00 balance transfers + 0.00 FINANCE CHARGES + 258.57 new balance = $11,593.36 You may be able to avoid Periodic Finance Charges, see the reverse side for details. Cashback Bonus® Cashback Bonus® Anniversary Date: April4 Opening Cashback Bonus Balance $ 29.85 New Cashback Bonus Earned + 0.00 Cashback Bonus Balance $ 29.85 Available to Redeem $ 0.00 Transactions trans. post date date Other/Miscellaneous Nov 4 Nov 4 LATE FEE Nov 4 Nov 4 OVERLIMIT FEE $ 39.00 35.00 """' ATTENTION ".. ATTENTION --* ATTENTION """' ATTENTION "'"" ATTENTION We previously requested the past due amount on your account. We have no record of receiving payment. The amount due should be paid at once. Balance Transfer offer for current billing period: Daily Periodic Rate: 0.07326%; corresponding ANNUAL PERCENTAGE RATE: 26.74%. Rate is subject to the terms of the offer including expiration. Nominal Transaction Average Daily ANNUAL ANNUAL Periodic Fee Daily Periodic PERCENTAGE PERCENTAGE FINANCE FINANCE Balances Rates RATES RATES CHARGES CHARGES current billing period: 31 days Purchases $4155.36 0.07326% 26.74% V 26.74 % $94.37 none Cash Advances $7230.06 0.07326% 26.74% V 26.74% $164.20 $0 The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above. Questions? Call 1-800-DISCOVER (1-800-347.2683) or log on to Oiscovercard.com. For TDD "pay" tv (Telecommunication Device for the Deaf) assistance, call 1-800-347-7449. Send billing eaor notice to: DISCOVER Discover Platinum; P.O. Box 15192; Wilmington, DE 19850-5192. VERIFICATION The undersigned does hereby verify subject to the penalties of 18 Pa. C.S. §4904 relating to unsworn falsification to authorities, that he is an attorney for the Plaintiff herein and makes this Verification based upon the facts as supplied to him by the Plaintiff because the Plaintiff is outside the jurisdiction of the court and the Plaintiff's Verification cannot be obtained within the time allowed for the filing of this pleading; and that the facts and circumstances set forth in this pleading, are true and correct to the best of her knowledge, information and belief. L Lrl ? w C - :. SHERIFF'S RETURN - REGULAR CASE NO: 2006-00498 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS BONURA SHARILYN MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BONURA SHARILYN the DEFENDANT at 1857:00 HOURS, on the 31st day of January 2006 at 3904 PARK CIRCLE HILL, PA 17011 by handing to SHARILYN BONURA a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 11.44 Affidavit .00 Surcharge 10.00 .00 39.44 Sworn and Subscribed to before me this _ 6 day of dao ' A. D. G' Prot al So Answers: R. Thomas Kline 02/01/2006 WELTMAN WEINBERG REIS By: Deputy Sh iff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. SHARILYN BONURA Defendant No. 06-498 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: WILLIAM T. MOLCZAN, ESQUIRE PA I.D.447437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04908412 Judgment Amount $ 13093.36 THIS LAW FIRM IS ATTEMPTING TO COLLECT THIS DEBT FOR ITS CLIENT AND ANY INFORMATION OBTAINED WILL 13E USED FOR THAT PURPOSE. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 06-498 CIVILTERM SHARILYN BONURA Defendant TO THE PROTHONOTARY: PRAECIPE FOR DEFAULT JUDGMENT Kindly enter Judgment against the Defendant, SHARILYN BONURA above named, in the default of an Answer, in the amount of $13093.36 computed as follows: Amount claimed in Complaint $11593.36 Interest from date of judgment at the legal interest rate of 6.00% per annum Attorney's fees $1500.00 TOTAL $13093.36 I hereby certify that appropriate Notices of Default, as attached have been mailed in accordance with PA R.C.P. 237.1 on the dates indicated on the Notices. WELTMAN, WEINBERG & REIS CO_, L.P.A. By: WILLIAM T. MOLC AN, QUIRE PA I.D.#47437 Wellman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W W R#04908412 Plaintiff's address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7"' Avenue, Pittsburgh, PA 15219 And that the last known address of the Defendant is: 3904 PARK CIR CAMP HILL,PA 17011 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. SHARILYN BONURA Defendants TO: SHARILYN BONURA 3904 PARK CIR CAMP HILL,PA 17011 Civil Action No. 06-498 CIVIL TERM IMPORTANT NOTICE Date of Notice: aI Z; ll c(v 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 NOTICE TO A LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE FOLLOWING OFFICE TO FIND OUT WHERE YOU CAN GET LEGAL HELP. LAWYER REFERRAL SERVICE CUMBERLAND COUNTY BAR ASSOCIATION 32 SOUTH BEDFORD STREET CARLISLE, PA 17013 (717) 249-3166 WELTTMAANN, W?EINBERG & REIS CO., L.P.A By: William T. Molczan PA I. D. #47437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #04908412 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. SHARILYN BONURA Case no: 06-498 CIVIL TERM NON-MILITARY AFFIDAVIT Defendant The undersigned, who first being duly sworn, according to law, deposes and states as follows: That he/she is the duly authorized agent of the Plaintiff in the within matter. Affiant further states that the within Affidavit is made pursuant to and in accordance with the Servicemembers' Civil Relief Act (SCRA), 50 U.S.C. App. § 521. Affiant further states that based upon investigation it is the affiant's belief that the Defendant, SHARILYN BONURA is not in the military service. Affiant further states that this belief is supported by the attached certificate from the Defense Manpower Data Center (DMDC), which states that the Defendant, SHARILYN BONURA is not in the military service. Further Affiant sayeth naught. AFFIANT SWORN TO AND SUBSCRIBED in my presence this J day COMMONWEALTH OF PrNNSYLVANIA i Notarieal seal -? Heidi .I. Kerry, Notary Public OTARY PH City Of Pittsburgh, Allegheny County My Commission Expires Nov. 4.2009 Member.. Pennsylvania Association of Notaries 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. Request for Military Status Department of Defense Manpower Data Center .k ` Military Status Report Pursuant to the Service Members' Civil Relief Act Page 1 of 1 MAR-13-2006 10:58:58 ?K Last Name First/Middle Begin Date Active Duty Status Service/Agency BONURA SHARILYN Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, the above is the current status of the individual, per the Information provided, as to all branches of the Military. rJl?? ? ?? Cam. Robert J. Brandewie, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Service Members Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief 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 rate. In the event the individual referenced above, or any family member, friend, 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 encouraged to contact us by phone at (703-696-6762). We will then conduct further research. Your failure to re-contact DMDC may cause provisions of the SCRA to be invoked against you. This response reflects current active duty status only. For historical information, please contact the military services SCRA point of contact. See: http://www.defenselink.mi1/faq/pis/PC09SLDR.html. WARNING: This certificate was provided based on a name and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. Report !D: ZVDEXMXAXD https://www.dmdc.osd.mil/scra/owa/scra.pre_Select 3/13/2006 c ? ? VI? IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 06-498 CIVIL TERM SHARILYN BONURA Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Judgment was entered against you on /YJ ?n a,a a,l?D? i (xx) Assumpsit Judgment in the amount of $13093.36 plus costs. ( ) Trespass Judgment in the amount of $ plus costs. ( ) If not satisfied within sixty (60) days, your motor vehicle operator's license and/or registration will be suspended by the Department of Transportation, Bureau of Traffic Safety, Harrisburg, PA. (xx) Entry of Judgment of ( ) Court Order ( ) Non-Pros ( ) Confession (xx) Default ( ) Verdict ( ) Arbitration Award Prothonotary ??, By. / PROPINOTARY (OR DEPUTY) 24 ?_,_r, SHARILYN BONIJRA 3904 PARK CIR CAMP HILL,PA 17011 Plaintiffs address is: c/o Weltn an , Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7° Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. SHARILYN BONURA Defendant No. 06-498-CIVIL TERM PRAECIPE FOR SATISFACTION OF JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt, Esquire PA. I. D.#42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 1400 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#4908412 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 06-498-CIVIL TERM SHARILYN BONURA Defendant PRAECIPE FOR SATISFACTION OF JUDGMENT At the request of the undersigned attorneys for the Plaintiff, you are directed to satisfy the above-captioned Judgment. WELTMAN, WEINBERG & REIS CO., L.P.A. By_ - r brodt, Esquire PA. I. D4 WELTINBERG & REIS CO., L.P.A. 1400 KBuilding James /-7955 436 SeAvenue Pittsbu15219 (412) 4 WWR #4908412 Sworn to and subscribed. before me this day of AUGU 0 _ CGU[t1DoV?l1°t'. PE"1SYL\',".*`.' Wendy L. Gael:, f+?.otary Public NOT ,*Y PU LI C cPiurgn, P>ii: g+^env county My Member, n :c :ir _s ,,uly 15, 2010 , Pennsyiv , <« al ion of hsotaries ?..a Q? IWO a 94 ?. .Ci .X ? V' t'7 x . :'a Cam.? ,57