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Home My WebLink About06-0867 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: 7 Vs. COMPLAINT IN CIVIL ACTION ROBERT RITTER 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 04521836 C A Pit WLG IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. ROBERT RITTER Defendant Civil Action No 0t,' (-7 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: ROBERT RITTER 69 BIG SPRING TER NEWVILLE, PA 17241 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011002740571732 . 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 February 03, 2006 , in the amount of $6520.31 . 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 $1000.00 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 , ROBERT RITTER INDIVIDUALLY , in the amount of $6520.31 with interest at the legal rate of 6.000% per annum from date of judgment plus attorneys' fees of $1000.00 , and costs. James C.?W rmbrodt,42524 WELTMAN, nINBERG L REIS CO., L.P,A. 436 Seven Avenue, Suite 2718 Pittsbur PA 15219 (412) 43 - 955 FAX: 412 38-7130 04521836 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 / r $ August 9, 2004 Please make check payable to Discover Card. You are overlimit. Pay the sum of the monthly minimum payment plus the overlimit amount of $4,546.93. 10 SDSN6A01 0001583 ROBERT RITTER To order Cash Access Checks, select 69 BIG SPRING TER your P.M., or to find cash locations call 1-800-DISCOVER (1-800-347-2683) or NEWVILLE PA 17241-9108 visit Discovercard.com. JAN 2 4 2006 PO Box 15251 III It 11111 twill 111111lt It 11 WILMINGTON DE 19886-5251 Address or telephone change? Please print change in the space above, IIUIIIIInInIIl I I I I ill u I l l l u I l i l I I I l n l Ill l l l l I III llttl or go to Discovercard.com. 000006011002740571732065469300000000083900 Discover Card Account Summary Closing Date: July 10, 2004 page 1 of 2 previous balance $6,380.60 account number 6011 0027 4057 1732 payments and credits - 0.00 payment due date August 9, 2004 purchases + 50.00 minimum payment due $839.00 cash advances + 0.00 credit limit $2,000.00 credit available $-4,546.00 balance transfers + 0.00 cash credit limit $1,000.00 FINANCE CHARGES + 116.33 cash credit available $0.00 new balance = $6,546.93 You may be able to avoid Periodic Finance Charges, see the reverse side for details. EXHIBIT Cashback Bonus® Opening Cashback Bonus Balance New Cashback Bonus Earned $ 0.00 + 0.00 Cashback Bonus Balance $ 0.00 Available to Redeem $ 0.00 Cashback Bonus® Anniversary Date: Septerrlber 10 Transactions trans. post date date previous statement balances FINANCE CHARGES: OLD BALANCE $ 0.00 FINANCE CHARGES: CASH 0.00 FINANCE CHARGES: PURCHASES 0.00 FINANCE CHARGES: BALANCE TRANSFERS 0.00 PRINCIPAL: OLD BALANCE 0.00 - - - PRINCIPAL: CASH.. -----0:00---- PRINCIPAL: PURCHASES 0,00 PRINCIPAL: BALANCE TRANSFERS 0.00 tran date post date Jul 10 Jul 10 LATE FEE 25.00 Jul 10 Jul 10 OVERLIMIT-FEE 25.00 """" ATTENTION """" ATTENTION """" ATTENTION """" ATTENTION """' ATTENTION Your account is seriously past due. Payment of the amount due and arrangements for future payments should be made immediately. 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. 04521836 C A Pit WLG E L'> IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. ROBERT RITTER Defendant No.: 06-867 CIVIL PRAECIPE FOR ENTRY OF JUDGMENT BY CONSENT 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 WWR404521836 IN 'THECOURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. ROBERT RITTER Defendant TO THE PROTHONOTARY: Civil Action No.: 06-867 CIVIL PRAECIPE FOR JUDGMENT BY CONSENT Kindly enter Judgment against Defendant. Robert Ritter, in the amount of $7520.31 Plus costs. based upon the consent of the parties. CONSENTED TO: WELTMAN, WEINBERG & REIS CO., L.P.A., ROBERT RITTER By: Att orney for Pla' iti Defendant WWR#0452 3 J a I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No.: 06-867 CIVIL ROBERT RITTER Defendant NOTICE OF JUDGMENT OR ORDER TO: ( ) Plaintiff (xx) Defendant ( ) Garnishee You are hereby notified that the following Order or Jud ment was entered against you on -aff ;L,0U(o (xx) Assumpsit Judgment in the amount of $7520.31 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 ( ) Default ( ) Verdict ( ) Arbitration ( ) Award (XX) By Consent Prothonotary ROBERT RITTER 69 BIG SPRING TER NEWVILLE,PA 17241 By: dal;?ZL PROTH OTARY EPU Y) SHERIFF'S RETURN - REGULAR CASE NO: 2006-00867 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS RITTER ROBERT ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon RITTER ROBERT the DEFENDANT at 1435:00 HOURS, on the 24th day of February , 2006 at 69 BIG SPRING TERRACE NEWVILLE, PA 17241 by handing to BARBARA RITTER, WIFE 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 10.56 Affidavit .00 Surcharge 10.00 .00 38.56 Sworn and Subscribed to before me this ;) laf day of .260 (, E?A?D D. Proth aryl So Answers: R. Thomas Kline 02/27/2006 WELTMAN WEINBERG REIS By Deputy Sheriff 1 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff Vs. ROBERT RITTER Defendant ORRSTOWN BANK, Garnishee, No. 06-867 CIVIL PRAECIPE FOR WRIT OF EXECUTION (BANK ATTACHMENT ONLY) 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. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#04521836 ?% V IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 06-867 CIVIL ROBERT RITTER 49 1? SpPju ,y "'?, efendant ORRSTOWN BANK, 4.27 S?/o.+e?iralq? (7a, (?aALr?' PA 17043 Garnishee PRAECIPE FOR WRIT OF EXECUTION TO THE PROTHONOTARY: Kindly issue a Writ of Execution in the above matter... 1. directed to the Sheriff of Cumberland County: 2. against Robert Ritter, Defendant 3. against Orrstown Bank, Garnishee 4. Judgment Amount $ 7,520.31 Less payments of -(700.00) Interest $ 95.33 Costs $ SUBTOTAL: $ 6,915.64 Costs (to' be added by Prothonotary): $ WELTMAN, WEINBERG & REIS CO.,,L.P.A. v By James armb odt, Esquire WWEINBERG & REIS CO., L.P.A. PA Iruv;enth A2524 27 s Building 43 Avenue PiA 15219 (412) 434-7955 WWR#04521836 n -40 5 . w 1 i 1? r? t WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) COUNTY OF CUMBERLAND) NO 06-867 Civil CIVIL ACTION - LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due DISCOVER BANK, Plaintiff (s) From ROBERT RITTER, 69 BIG SPRING TER, NEW VILLE, PA 17241 (1) You are directed to levy upon the property of the defendant (s)and to sell (2) You are also directed to attach the property of the defendant(s) not levied upon in the possession of ORRSTOWN BANK, 427 STONEHEDGE DR., CARLISLE, PA 17013 - GARNISHEE GARNISHEE(S) as follows: and to notify the garnishee(s) that: (a) an attachment has been issued; (b) the garnishee(s) is enjoined from paying any debt to or for the account of the defendant (s) and from delivering any property of the defendant (s) or otherwise disposing thereof; (3) If property of the defendant(s) not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee, you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due $6820.31 L.L. $.50 Interest $95.33 Arty's Comm % Due Prothy $1.00 Any Paid $121.06 Other Costs Plaintiff Paid Date: JUNE 30, 2006 CURTIS R. LONG Prothono (Seal) Deputy REQUESTING PARTY: Name JAMES C. WARMBRODT, ESQUIRE Address: WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 KOPPERS BUILDING 436 SEVENTH AVENUE PITTSBURGH, PA 15219 Attorney for: PLAINTIFF Telephone: 412-434-7955 Supreme Court ID No. 42524 ,401 IN 'f LIF, COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL. DIVISION DISCOVER BANK Plaintif x S. ROBER"I RITTER Defendant ORRSI'OW'N BANK Garnishee No. 06-86' CIVIL PRAECIPE TO SETTLE, DISCONTINUE & END AS TO THE GARNISHEE ORRSTOWN BANK ONLY FILED ON BEHALF Of Plaintiff COUNSEL OF RECORD OF THIS PARTY: James C. Warmbrodt PA LD #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building =436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 W W R No. 04521836 J IN T1113 COURT OF COMMON ['LEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. R013ER 1 R11THR Defendant ORRS TOWN BANK Garnishee Civil Action No. 06-867 CIVIL PRAECIPE TO SETTLE, DISCONTINUE AND END AS TO THE GARNISHEE ORRSTOWN BANK ONLY TOT! 11, PRO H IONOTARY OF COUNTY: PL:as: kindh Settle Discontinue and End the above captioned matter as to Garnishee,' ORRSTOWN BANK, only, upon the records of the Court and mark the cost paid. WF,LFMAN, WEINBFERG & RLIS CO., L.P A Sworn to and subscribed Before me the Day oi'July, 2006 N 1-ARl' P BLIC'. COMMONWEALTH OF PENNSYLVANIA Notaft Seat A- JWWW Notely Public CMy01Plfur01%AU{/"County W CarrmbNon BOO June 2G, 2010 Member, Penneylvenle Aseooledw of Nofula By' 7ers Jamd PA WEBERG & RE.IS CO., L.P.A. 271 ing 436 e Piti19 (41W W R No. 04521836 s. /?zI ..0 C? 1 V N Zx" 0 ct? a -n CJ 7 x f, ' SHERIFF'S RETURN - GARNISHEE CASE NO: 2006-00867 P COMMONWEALTH OF PENNSLYVANIA COUNTY OF CUMBERLAND DISCOVER BANK VS RITTER ROBERT And now DAVID MCKINNEY Sheriff or Deputy Sheriff of Cumberland County of Pennsylvania, who being duly sworn according to law, at 0015:27 Hours, on the 6th day of July 2006, attached as herein commanded all goods, chattels, rights, debts, credits, and moneys of the within named DEFENDANT RITTER ROBERT hands, possession, or control of the within named Garnishee ORRSTOWN BANK 22 S. HANOVER ST CARLISLE, PA 17013 Cumberland County, Pennsylvania, by handing to JACKIE JUMPER (HEAD TELLER) personally three copies of interogatories together with 3 and attested copies of the within WRIT OF EXECUTION the contents there of known to His . Sheriff's Costs: Docketing .00 Service .00 Affidavit .00 Surcharge .00 in the true and made So answers: Thomas Kline Sheriff of Cumberland County .00? 71.2,1607/10/2006 Sworn and Subscribe to before me this day of By Deputy Sheriff A.D HTA Discover Bank Robert Ritter VS 21@9 SEP 30 AM 10-- 17 Writ of Execution CUM ??? C}'Y Docket No. 2006-867 Civil Term R. Thomas Kline, Sheriff, who being duly sworn according to law, states this writ is returned ABANDONDED. Sheriffs Costs: Docketing $18.00 Surcharge 30.00 Garnishee 9.00 Levy 20.00 Mileage 4.40 Poundage 1.66 Prothonotary 1.00 Law Library .50 ?%v?a?b9••. $84.56 So Answers: R. Thomas Kline, Sheriff BY G :J Sergeant uL) CP CP, 7.2 70 G :7 31 a -13