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Home My WebLink About06-0755 STOCK & GRIMES, LLP BY: EJJNARD STOCK, ESCPIRE LD. # 13657 804 West Avenue Jenkintown, PA 19046 (215) 576-1900 Attorney for Plaintiff DISCOVER BANK, ISSUER OF DISCOVER CARD, BY ITS AGENT DISCOVER FINI'.NCIAL SERVICES, LLC P.O. Box 6011 Dover, DE 19903-6011 COURT OF COMMON PLEAS CUMBERL'lliD C;) U N T Y CIVIL ACTION-LAW vs LAURA L. FORSLUND 5402C Oxford Drive Mechanicsburg, PA 17055-8305 010.0(", -7SS ciolTSL~ CIVIL l\Cl'ICN "NOTICE" "You h"w€ been sued in court. 11 you wish to'defend agJinst the cl<lims set forth in the fo\~ lowing pages, you must tiJke action within twenty (20) days after this conlplait1t and nctice are served, by entering <1 written appdar<1nce person- ally or by attorney 8nd filing in writlng with the court your defenses or obiections to the clafms set forth against you. You are warned th;]t -if you fai I to do so the case lllilY proceed without you and a judgment may be entered against you by the court without further notice for any money clclimed in the complaint or for any other cla(rn or relief requested by tile plaintiff. You may lose money or property or other rights important to you. "AVISO" "Le han demandado a usted en la corte. Si usted qui ere defenderse de estas demandas ex- puestas en las pagin.1s siguientes, usted tiene ve)nte (20) dias de plaza al partir de la fecha de la demand;] y la notificacion. Hace talla asentar una camparencl3 escrita a en persona 0 con un abogado y entregar a la corte en forma escrita SuS defensas 0 sus objeciones alas demandas en contr<.l de su persona. Sea avi sado que sj usted no se de-fiende, la corte tomara medidas y puede continuar lE1 demanda en contra suya sin previo aviso 0 notilicacion. Ademas, 18 -corte puede decidir a favor del demandante y requiere que usted cumpliJ con todas las provisiones de esta demanda. Usted puede perder dinero 0 sus propiedades U olros derechos importantes para usted." "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 CIIN GET LEGAL HELP. "LLEVE ESTA DEMANDA A UN ABO- GADO INMEDIATAMENTE. SI NO TIENE ABO- GADO 0 SI NO TIENE EL DINERO SUFICIENTE DE PAGAR T.'IL SERVICIO, VAYA EN PER- SONA 0 LLAME POR TE,LEFONO A LA OFI- CINA CUY A DIRECCION SE ENCUENTRA ESCRITA ABAJO 'IRA AVERIGUAR DONDE SE PUEDE COi~SE IIR ASISTENCI LEGAL. Lll,WYER CE SERVICES Court 1l,Quinistrator -- euuberland CoW1ty Courthouse 4th Floor, One Courthouse Square carlisle, P~ 17013 (717) 240-6200 STOCK & GRIMES, LLP BY: EDWARD STOCK, ESQUIRE I.D. #13657 804 West Avenue Jenkintown, PA 19046 (215) 576-1900 DISCOVER BANK, ISSUER OF DISCOVER CARD, BY ITS AGENT DISCOVER FINANCIAL SERVICES, LLC P.O. Box 6011 Dover, DE 19903-6011 Plaintiff vs. LAURA L. FORSLUND 5402C Oxford Drive Mechanicsburg, PA 17055-8305 Defendant Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION-LAW NO. Ol.. - 75'S CloL'-r~ CIVIL ACTION COMPLAINT IN ASSUMPSIT 1. Plaintiff, Discover Bank, issuer of Discover Card, by its agent Discover Financial Services, Inc., is a duly organized banking institution under the laws of the State of Delaware and has a principal place of business at the address contained in the above caption. 2. Defendant(s), LAURA L. FORSLUND, is an adult individual and resides at the address contained in the above caption. 3. After application by the Defendant(s) to the Plaintiff for a credit card account, which application was approved by the Plaintiff, the Plaintiff issued a credit card to the Defendant(s) so that the Defendant(s) could make purchases from merchants, on credit, who had established a business relationship with the Plaintiff in regard to the same. 4. Thereafter, the Defendant(s) utilized the said credit card on various and sundry occasions. 5. plaintiff attaches hereto as Exhibit "A" to this Complaint, a true and correct copy of the last monthly statement in regard to the activities in connection with the Defendant's account and also attaches hereto as Exhibit "B" to this Complaint, an Affidavit from the Plaintiff attesting to the present balance due the Plaintiff from the Defendant(s) in regard to the said account. 6. Notwithstanding repeated requests and demands of the Plaintiff upon the Defendant(s) to satisfy the outstanding indebtedness in the sum of $8,078.37 the Defendant(sl has/have and still refuse(s) to pay the same. 7. As a result thereof, Plaintiff has been forced to incur reasonable attorney collection fees in the sum of $2,019.59 in an attempt to legally enforce collection of the debt due it from the Defendant(s), which reasonable attorney fees are the responsibility of the Defendant(s) to pay in accordance with the Cardmember Agreement. 8. Plaintiff's investigation has determined that the Defendant is not in the military service. 9. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. WHEREFORE, Plaintiff, Discover Bank, issuer of Discover Card, by its agent Discover Financial Services, LLC., demands Judgment against the Defendant(sl, LAURA L. FORSLUND, in the sum of $10,097.96, with interest and costs. ; /j()-()G DATE: -\ , / VERIFICATION EDWARD STOCK, ESQUIRE, Attorney for the Plaintiff herein, verifies that the statements made in this Pleading are true and correct and that he is authorized to make them on behalf of the Plaintiff. He lmderstands that the statements herein are made subject to the penalties ofPa. C.S.A. Sec. 4904, relating to unsworn falsification to authoriti(':s. /1 ;/ D~SC VER new balance $0.00 CARD 30 SDSNliA01 0006376 LAURA FORSLUND 5402C OXFORD DR MECHANICSBURG PA 17055-8305 minimum payment due $1,485.00 ?CCOWlt numher 6011 0027 4070 9647 t'fIt!::!r Alllount enclosed Vcluw payment dlle dale December 29, 2005 $L To order Cash Access Checks, select pur P.J.N., or to find cash locations call 1-800.DISCOVER (1-800-347.26831 01 visit Oiscovercard.com. PO BOX 15251 11I...11.....11.11",1.,,11 WILMINGTON DE 19886-5251 Addrf"ss or telef.,honti change? Please print change in the space above, 1'11111,1111111.1111111111.1,11111,1.1,1"1111,1.1111111/.1111 0' go fO DfscovErCBrdwm. 000006011002740709647000000000000000148500 Discover Platinum Card Account Summary account nUmbE'( paymtmt due date minimum payment due cmditfimit crodit available cash credit limit ca.5h credit available 6011 002740709647 December 29, 2005 $1,485.00 $6,000.00 $0.00 $3,000.00 $0.00 Closing Date: No.ember 30, 2005 page 1 of 1 Previou~~a~nce ______ _____ __J_8,07~,3~ payments_ arid credit'~____,~,___________~~~?2 purchases + 0.00 ..--- --..-- ---.'-.-----...--.,----..--- cash advances + 0.00 -',._--.-------'''-._- .---'--..-.----.----..---- balance transfers + 0.00 ----._-,---.._-,- --------.-------.----- --- FINANCE CHARGES + 0.00 --.----------.-------.-----..,-----------------.- new balance = $0.00 Cash back BonusiBl $ + Cashback Bonus@ Anniversary Date: July 13 Opening Cashback Bonus Balance New Cashback Bonus Earned 0.00 0.00 0.00 0.00 Cashback Bonus Balance Available tD Redeem $ $ Transactions trans. post date date Payments and Credifs Nav 30 Nov 30 INTERNAL CHARGE.OFF $ -8,078.37 Exhibit "A" Average Daily Balances Dally Periodic Rates current bUling period: 17 days ~'lJ;;;n~L ANNUAL PERCENTAGE PERCENTAGE RA TES RA TES Periodic FINANCE CHARGES Transaction Fee FINANCE CHARGES ATTORNEY: ACCOUNT NUMBER: BALANCE: CARDMEMBER (S): STOCK 6011002740709647 $8078.37 LAURA L FORSLUND STATE OF OHIO COUNTY OF FRANKLIN R. Jones, personally appeared before me, this day and after being duly sworn, according to law, upon his/her oath and says: I am a Legal Placement Account Manager for DISCOVER FINANCIAL SERVICES LLC., the servicing agent of DISCOVER BANK, an FDIC imured Delaware State Bank. THAT this affidavit is made on the basis of my personal knowledge and in support of Plaintiffs suit on account against the Debtor(s) THAT, in my capacity as Legal Placement Account Manager, I have control over and access to records regarding the Discover Card Account of the above referenced Debtor(s), further, that I have personally inspected said Account and statements regarding the balance due on said account. DISCOVER FINANCIAL SERVICES, LLC. maintains these records in the ordinary course of business. THAT the annexed statement of account is a true and correct statement of what is now due and owing Discover Bank on the account, and exhibit A is a copy of the Cardmember Agreement between Discover Bank and the above referenced Debtor(s). The Cardmember Agreement governs the tenus and conditions of the relationship between Discover Bank and the Debtor(s) in connection with the account. Based on my review of the account records, to the best of my knowledge and belief the above referenced Debtor(s) is not engaged in the military service of the United States and is a resident of the State and of the Country in which this action has been filed. I declare under penalty of perjury that the foregoing is true and correct to the best of my knowledge. Affiant Sworn and Subscribed before me, This day of Wednesday, December 07,2005. Exhibit "B" ,\\\tllll"lt, ,-} 1>..'B-.'f..l!.U;:' '.~~' \If ',v.', ::~'q.,~ ,\, ..//j''(-'!.', -lii~''''' .. ;~: " \",... ~*! ~:*~ _ t - :. ... : ,OX. /.1 :: '....d'S ..,~~,' ;.'~.-r:..""".'''''O'-';~' . .. O~ " ."tllIh\\\ KRIS LAROSA NaIrIy Public, Stale 01 Ohio My Commission Ellpires ~ 25,2010 v~~ NOT 'Request for Military Status Page I of I Department of Defense Manpower Data Center JAN-03-200612:18:44 Military Status Report Pursuant to the Service Members' Civil Relief Act -<. Last First/Middle Begin Date Active Duty Status Service/Agency Name FORSLUND LAURA L 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. ~wr;&u-~ 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. 99 501 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 ofthe 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.miilfaq{pis/PC09SLDR.hlInL ReportlD:UTRVUOTGYY https://www.dmdc.osd.miilscra/owa/scra.prc_Select 1/3/2006 () -to. N U1 G \ r-.':> C) (f'l C^; c__' -n \\- __:1 { ,-:r.... ._1 """" ~i'~ -1"1 V"l r". rn~\ C:; -n'_",_~ 0- \ -"'1..-/ - C""' 1."'" - '-.J " ~ ~ .c. '. ~ r') c:f""i1. ~ .c:. I.,) lI'\ f..;"? -(:..,; ~ ,-:"",) ';1) CY .-" l~-.,' -----t... .-.------- SHERIFF'S RETURN - REGULAR CASE NO: 2006-00755 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS FORSLUND LAURA L CPL. TIMOTHY REITZ Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon FORSLUND LAURA L the DEFENDANT , at 1801:00 HOURS, on the 13th day of February, 2006 at 5402C OXFORD DRIVE MECHANICSBURG, PA 17055-8305 by handing to LAURA L FORSLUND 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 Service Affidavit Surcharge So Answers: 18.00 9.68 .00 10.00 .00 37.68 r~~.,~d R. Thomas Kline 02/14/2006 STOCK & GRIMES Sworn and Subscribed to before me this (:;3(d day of By: -' --;7l/) 'j/'<..- / ..' /. /~ ,J ~-vt/. / /"'t- II Deruty She ff A.D. STOCK & GRIMES, LLP BY: Edward Stock, Esquire I.D.#13657 804 West Avenue Jenkintown, PA 19046 (215) 576-1900 DISCOVER BANK, ISSUER OF DISCOVER CARD BY ITS AGENT DISCOVER FINANCIAL SERVICES, LLC P.O. Box 6011 Dover, DE 19903-6011 Plaintiff vs. LAURA L. FORSLUND 5402c Oxford Drive Mechanicsburg, PA 17055-8305 Defendant(s) # Attorney for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION-LAW NO. 06-755 Civil PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Enter Judgment by Default in favor of the Plaintiff, Discover Bank, issuer of Discover Card by its agent Discover Financial Services, LLC, and against the Defendant(s), Laura L. Forslund, for failure to Answer the Civil Action Complaint. Assess Plaintiff's damages in the sum of $10,097.96 in accordance with the prayer of the Complaint. DATE: 4",h ~6 . . ... AFFIDAVIT OF NON MILITARY SERVICE Edward Stock, Esquire, being duly sworn according to law, deposes and says: (a) That the Defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1 94C, as amended; (b) That Defendant, Laura L. Forslund, is an adult individual and resides at 5402C Oxford Drive, Mechanicsburg, P A 17055-8305. (c) That Defendant, , is an adult individual and resides at Affiant has ascertained the foregoing information by personal investigation and makes this Affidavit in due authority; and he understands that the statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904, relating to unsworn falsification to authorities. z/ ---..., . . DISCOVER BANK, ISSUER OF DISCOVER CARD BY ITS AGENT DISCOVER FINANCIAL SERVICES, LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION-LAW plaintiff NO. 06-755 Civil vs. LAURA L. FORSLUND Defendant(sJ CERTIFICATION UNDER PA. R.C.P. 237.1 EDWARD STOCK, ESQUIRE, Attorney for Plaintiff, Discover Bank, issuer of Discover Card by its agent Discover Financial Services, LLC, certifies that he sent a copy of the attached Notice on March 14, 2006 by regular mail, to the Defendant(s) at the address at which the Defendant(s) was/were served with a copy of the Complaint by the Office of the Sheriff indicated by the court records. DATE: EDWARD STOCK, ESQUIRE Attorney for plaintiff , . DISCOVER BANK, ISSUER OF DISCOVER CARD BY ITS AGENT DISCOVER FINANCIAL SERVICES, LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION-LAW Plaintiff vs. NO. 06-755 Civil LAURA L. FORSLUND Defendant( s) TO: Laura L. Forslund 5402C Oxford Drive Mechanicsburg, P A 17055-8305 Date: March 14,2006 IMPORT ANT NOTICE YOU ARE IN DEF AUL T 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 (10) DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAYBE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MA Y 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 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 MAYBE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER . . LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. LAWYER REFERENCE SERVICES COURT ADMINISTRATOR - CUMBERLAND COUNTY COURTHOUSE 4TH FLOOR, ONE COURTHOUSE SQUARE CARLISLE, PA 17013 (717) 240-6200 ~i' EDWARD STOCK, ESQUIRE Attomey for Plaintiff 804 West Avenue Jenkintown, PA 19046 (215) 576-1900 o j5 t ~ '- 'B 'i- _ ~ -J ~ ~ -:z ~ 'R---:tn ~ ~ +- Il!!, ~ r--- ,- ( >~ (,-, , :'-;:1 ~ .--\ -<'," -, :-- \\1 :. -' ,-I' \ c.."', -,,-, r ~\ c,)