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Home My WebLink About06-3265 I IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. JEFFREY S CHAPWICK Defendant No: cxe- 221,015 C,utC-- ? 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 05184066 C A Pit WLG l IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No JEFFREY S CHAPWICK 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 4 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: JEFFREY S CHAPWICK 1907 SPRING RD CARLISLE, PA 17013 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011001282080854 . 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 May 22, 2006 , in the amount of $11994.50 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 , JEFFREY S CHAPWICK INDIVIDUALLY , in the amount of $11994.50 with interest at the legal rate of 6.000% per annum from date of judgment plus attorneys' fees of $1500.00 , and costs. Jame C. armbrodt,42524 WEL AN, WEINBERG & REIS CO., L.P.A. 4V4066 eventh Avenue, Suite 2718 Pburgh, PA 15219 434-7955 412-338-7130 0 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. eo? 25 SDSN6A0t 0005362 JEFFREY CHAPWICK 1907 SPRING RD CARLISLE PA 17013-1156 paymantdoe date $ I I April 24, 2006 Please make check payable to Discover Gold Card. You are overlinia Pay the sum of the monthly minimum payment plus the overlimft amount of $994.50. Schedule payments in advance up to your due date) Find out about our flexible and convenient online payment features. Visit Discovercard.com/payments Address m telephone change? Pkiase print change in the space above, or go to Discovercard.com. PO BOX 15251 111111111191811111111331111 WILMINGTON DE 19886-5251 000006011001282080854119945000000000115000 Discover Gold Card Account Summary account number payment due date minimum payment due credit limit credit available cash credit limit cash credit available 6011 0012 8208 0854 April 24, 2006 $1,150.00 $11,000.00 $-994.00 $5,500.00 $0.00 Closing Date: March 25, 2006 page 1 of 1 previous balance $11,748.14 payments and rrad'c; - 0.00 purchases + 74.00 cash advances + 0.00 balance transfers + 0.00 FINANCE CHARGES + 172.36 new balance = $11,994.50 You may be able to avoid Pedodic Finance Charges, see the reverse side for details. °? 0041BI 9 11A81 ----- ---------- --------- - --- ------ Cashback Bonus Opening Cashbe Bonus Balance $ 0.00 ® New CashbadcBonus Eamed + 0.00 Cashback Bonus Balance $ 0.00 Available to Redeem $ 0.00 Cashback BonusO Anniversary Date: October 25 items. post date date Other/Miscellaneous Mar 25 Mar25 OVERLIMIT FEE $ 35.00 Mar 25 Mar 25 LATE FEE 39.00 ATTENTION-•••••••_ ATTENTION-••••••• ATTEW404.t"t't«-ATTENTION -t' t--ATTENTION-t't't-------- .-- ?, • our account is sedously past due. Payment of the amount due and arrangements for future payments should be made immediately. i Nominal Average Daily ANNUAL ANNUAL Periodic Transaction Fee Daily Panodre PERCENTAGE PERCENTAGE FINANCE FINANCE Balances Rates RATES RATES CHARGES CHARGES current billing period: 28 days Purchases $11831.02 0.05203% 18.99% V 18.99% $172.36 none Cash Advances $0 0.05751% 20.99% F 20.99% $0 $0 The rates that apply to your Account are either fixed (F) or they may vary (V) as noted above. VERIFICATION The undersigned does hereby verify subject to the penalties of, 18 PA.C.S. §4904 relating to unsworn falsifications to authorities, that he/she is /4?.K-GX-S (Name) X! ,G .f,(CIl'I - of Discover Financial Services. LLC., plaintiff herein, that (Title) (Company) he/she is duly authorized to make this Verification, and that the facts set forth in the foregoing Complaint in Civil Action are true and correct to the best of his/her knowledge, information and belief. (Signature) WWR # 5184066 JEFFREY S CHAPWICK 6011001282080854 N lJ r; ?; _ {?1T 1 cn v .4t SHERIFF'S RETURN - NOT FOUND CASE NO: 2006-03265 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DISCOVER BANK VS CHAPWICK JEFFREY S 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 CHAPWICK JEFFREY S but was unable to locate Him in his bailiwick. He therefore returns the COMPLAINT & NOTICE , NOT FOUND , as to the within named DEFENDANT , CHAPWICK JEFFREY S 1907 SPRING ROAD CARLISLE, PA 17013 PER REISDENT, DEFENDANT MOVED TO PERRY COUNTY. Sheriff's Costs: So answers : Docketing 18.00 '? Service 4.40 Not Found 5.00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County .00 37.40, Sworn and Subscribed to before me this day of A. D. WELTMAN WEINBERG REIS 06/22/2006 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. JEFFREY S CHAPWICK Defendant No. 06-3265-CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE 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#5184066 'Wb IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. 06-3265-CIVIL TERM JEFFREY S CHAPWICK Defendant PRAECIPE TO SETTLE DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE TO THE PROTHONOTARY OF CUMBERLAND COUNTY: SIR: Settle, Discontinue and End the above-captioned matter upon the records of the Court without prejudice to refile and mark the costs paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By: / James C. Wa rodt, Esquire PA I. D. #425 4 1400 Kopp s B ilding 436 Seven Av nue Pittsburg , PA 5219 (412) 43 -79 SWORN TO AND SUBSCRIBED before me this _-1_U_ day V 2008 Y PUBLI r _. Hc?i?i J K0, IV s ::! ci+y of Pry rr?. h.Ii i` ccmmi, MY Member PF ir: v - ._ IM .. as 61> '-C