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Home My WebLink About06-0611S I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. TIFFANY M WILHELM AKA TIFFANY WILHELM Defendant No: v(c - ?II ?fUt ?? 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 04917369 C A Pit WLG IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No 61,- `!l e1c"L ? TIFFANY M WILHELM AKA TIFFANY WILHELM 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: TIFFANY M WILHELM 226 CONSTITUTIONAL CT MECHANICSBURG, PA 17050 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011298795769128 . 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 17, 2006 , in the amount of $10175.89 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 , TIFFANY M WILHELM INDIVIDUALLY , in the amount of $10175.89 with interest at the legal rate of 6.000°% per annum from date of judgment plus attorneys' fees of $1500.00 , and costs. YF. Watmbrodt,47524 WEINBERG & REIS CO., L.P.A. nth Avenue, Suite 2718 rgh, PA 15219 34-7955 2-338-7130 9C 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. payment due date $ I??1 December 29, 2005 I I 30 SOSN6A01 0007897 TIFFANY WILHELM 226 CONSTITUTIONAL CT MECHANICSBURG PA 17050-1827 Address or telephone change? Please print change in the space above, or go to Discovercard.com. To order Cash Access Checks, select your P.I.N., or to find cash locations call 1-800-DISCOVER (1-800-347-2683) or visit Discovercard.com. PO BOX 15251 ???rrr??rrrtr??r??rrr?trr?? WILMINGTON DE 19886-5251 1111 1111 111111 111] 11 a IImIrItu IIIIIrIM1111MIMIII1Ir1I 000006011298795769128000000000000000186800 ------------ ---------- - -------- Discover Platinum Card Account Summary ------------- --------------- Closing Date: November 30, 2005 - ---- page 1 of 1 previous balance $10,175.89 account number 6011 2987 9576 9128 payments and credits - 10,175.89 payment due date December 29, 2005 purchases + 0.00 minimum payment due $1,868.00 credit limit $8,300.00 cash advances + 0.00 credit available $0.00 balance transfers + 0.00 cash credit limit $4,200.00 FINANCE CHARGES + 0,00 cash credit available $0.00 new balance = $0.00 E'A"HIBIT .t „ Opening Cashback Bonus Balance $ 0.00 Cashback Bonus® New Cashback Bonus Earned + 0.00 Cashback Bonus Balance $ 0.00 Available to Redeem $ 0.00 Cashback Bonus® Anniversary Date: April l7, Transactions trans. post date date Payments and Credits Nov 30 Nov 30 INTERNAL CHARGE-OFF $-10,175.89 ---- ------- --- ------------ Average ---------- Daily ------------- - - Nominal ANNUAL ANNUAL -------- Transaction Periodic Fee Daily Periodic PERCENTAGE PERCENTAGE FINANCE FINANCE Balances Rates RATES RATES CHARGES CHARGES current billing period: 13 days Purchases $0 0,07121% 25.99% V 25.99% $0 none Cash Advances $0 0.07121% 25.99% V 25.99% $0 $0 The rates that annly to vnnr Arrnunt me eBh- n.od ¢t ^,_ ..._.. ,on, nn o, nntnn ob - 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. 04917369 C A Pit WLG 1T-J?. q? ,,VM1M1 ?v ll v l LIA tri d -y? C) C- t f,R W T C? S' C> v T a 7 r? i ;c, SHERIFF'S RETURN - REGULAR CASE NO: 2006-00611 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS WILHELM TIFFANY M AKA TIFFANY CHAEL BARRI , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon WILHELM TIFFANY M AKA TIFFANY WILHELM the FENDANT , at 1836:00 HOURS, on the 2nd day of February , 2006 at 226 CONSTITUTIONAL COURT MECHANICSBURG, PA 17050 by handing to FFANY M WILHELM 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 13.20 Affidavit .00 Surcharge 10.00 .00 §1.20 Sworn and Subscribed to before C me this 7' day of -2 o-0 (, A . D . rotho ar So Answers: R. Thomas Kline 02/03/2006 WELTMAN WEINBERG REIS By:? I y eputSher f IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. TIFFANY M WILHELM AKA TIFFANY WILHELM Defendant No. 06-611 CIVIL TERM PRAECIPE FOR DEFAULT JUDGMENT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF TFIIS PARTY: WILLIAM T. MOLCLAN, ESQUIRE PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04917369 Judgment Amount $ 11,675.89 THIS LAW 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 CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 06-611 CIVIL TERM TIFFANY M WILHELM AKA TIFFANY WILHELM Defendant PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter Judgment against the Defendant, TIFFANY M W ILHELM AKA TIFFANY WILHELM above named, in the default of an Answer, in the amount of $17,675.89 computed as follows: Amount claimed in Complaint $10,175.89 Interest from date of judgment at the legal interest rate of 6% per annum Attorney's fees $1,500.00 TOTA I, $11,675.89 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: V !p ?/ WILLIAM T. MOLCZA , ESQUIRE PA I.D.#47437 Weltman, Weinberg & Reis Co., L.P.A. 2718 Koppers Bldg. 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04917369 Plaintiffs 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: 226 CONSTITUTIONAL CT., MEC IANICSBURG,PA 17050. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff TIFFANY M WILHELM Defendant(s) IMPORTANT NOTICE TO: TIFFANY M WILHELM 226 CONSTITUTIONAL CT MECHANICSBURG,PA 17050 Date of Notice: 0,31 0 A/ WWR#: 04917369 Case # 1?6 - 0 C ? l 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 TSBURGH,PA CARLISLE, PA 17013 (717) 249-3166 BY JAQUIRE PA WEREIS CO., L.P.A. 27436 7TH AVE. PI9 IN THE COMMON PLEAS COURT OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. TIFFANY M WILHELM AKA TIFFANY WILHELM Case no: 06-611 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, TIFFANY M WILHELM AKA TIFFANY WILHELM 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, TIFFANY M WILHELM AKA TIFFANY WILHELM is not in the military service. Further Affiant sayeth naught. AFFIANT SWOR O AND UB?CRIBED in my presence this ?D day of 2«?6. NOTARY PUBLIC _ 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 Military Status Report Pursuant to the Service Members' Civil Relief Act Page 1 of 1 MAR-17-2006 07:03:04 -<Last Name First/Middle Begin Date Active Duty Status Service/Agency WILHEIM 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. 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.mil/faq/pis/PC09SLDR._htrnl. 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 ID: BFXAFIDKZIM https://www.dmdc.osd.mil/scralowa/scra.prc_Select 3/17/2006 n ? ^_`/ ( 1 ? ? C ? ? ? ?c ? ? r- ? ;, . ? ? ? '' ` ? ? -?-- ? -: r-?. { ? IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 06-611 CIVIL TERM TIFFANYM WILHELM AKA TIFFANY WILHELM Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order yo?r`Judgment was entered against you on ......_d?t aCX>(o (xx) Assumpsit Judgment in the amount of $11,675.89 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: PROT NOT ( R DE JTY) TIFFANY M WILHELM - AKA 226 CONSTITUTIONAL CT MECHANICSBURG,PA 17050 Plaintiffs address is: c/o Weltman, Weinberg & Reis Co., L.P.A., 2718 Koppers Building, 436 7°i Avenue, Pittsburgh, PA 15219 1-888-434-0085 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. TIFFANY M WILHELM Defendant(s) No. 06-611 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) 434-7999 WWR#4917369 DIS IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 06-611 CIVIL TERM TIFFANY M WILHEL.M Defendant(s) 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: James C. W PA LD. # 1 WELTM 1400 K p thbrodt, Esquire 4 WEINBERG & RE IS CO., L.P.A. Building 436 Se e Avenue Pittsb , PA 15219 (412) .34-7999 WWR #4917369 Sworn to and subscribed before me this _3 day of December, 09 OTARY BLIC CCOM M C`''4VVEAU rsL ??'1',N?-!tV?"R A r7C"y Of _ u My Corn?, s .,., "tm>er: ?an^s%/ivanis sn,;ation of i N19DEC21 PM 2:3,, +8 S. oc> P o A"rl l C)C.-?t 143'7 t c 58 a353 t5