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Home My WebLink About06-7277 ~ IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No: Ot.. - 1.:1'77 (!,u.L~ ~ vs. COMPLAINT IN CIVIL ACTION HEATHER L COOK 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 05570214 C A Pit WLG IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No HEATHER L COOK 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 SHERIFF'S RETURN - REGULAR CASE NO: 2006-07277 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS COOK HEATHER L GERALD WORTHINGTON , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon COOK HEATHER L the DEFENDANT , at 2035:00 HOURS, on the 5th day of January , 2007 at 1098 COCKLIN STREET MECHANICSBURG, PA 17055 by handing to BELINDA LOUDON, ROOMMATE, ADULT IN CHARGE 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 80 Answers: Sworn and 8ubscibed to 18.00 17.60 .00 10.00 R. Thomas Kline .00_1 45.60{ 01/08/2007 ~ WELTMAN WEINBERG \,~~ ~~-..'<~.. REI8 before me this day BY~lA~~ Deputy 8 iff of A.D. COMPLAINT 1. Plaintiff, is a corporation with offices at 6500 NEW ALBANY ROAD NEW ALBANY , OH 43054 . 2. Defendant is adult individual(s) residing at the address listed below: HEATHER L COOK 1098 COCKLIN ST MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011002170674022 . 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 December 13, 2006 , in the amount of $1729.46 . 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 $300.00 . 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, HEATHER L COOK ,INDIVIDUALLY, in the amount of $1729.46 with interest at the legal rate of 6.000% per annum from date of judgment plus attorneys' fees of $300.00 , and costs. This law firm is a debt collector att our client and any information obtained -~ L.P.A. 2718 to collect this debt for be used for that purpose. DISCQVER- CARD $1,729.46 06 SDSN6AOi 0007228 HEATHER COOK 1143 SUMMERWOOD DR HARRISBURG PA 17111-4702 1$2'19.00' . -,,,,v,,, _vv Payment Due Date Octob~r 5, 2006 I E;t;~A~~~~t'E~'cIos;d B~lo-;-' . --. $1 5 S'-lC~ ~ IL( I Please make check payable to Discover Card. You are overlimit. Pay the sum ofthe monthly minimum payment plus the overlimit amount of $429.46. Save time and a stamp this month by paying your bill online. To find out about our free and flexible online payment features, visit Discovercard.com/payments Address, .mail or telephone change? Print change in space above, or go to Discovercard.com. Print your e-mail address to receive important Account information and special offers. PO BOX 15251 11I11I1111I1111111111I11111 WILMINGTON DE 19886-5251 1...111.1.111.1.11111.11.111.1..11.111.11...11.111.1..111.11.1 000006011002170674022017294600000000021900 Discover Card Account Summary 'Account Number ;Payment Due Date 'Minimum Payment Due Credit Limit Credit Available ~Cash Credit Limit Cash Credit Available 6011 0021 70674022 October 5, 2006 $219.00 $1,300.00 $..429.00 $700.00 $0.00 'Cashback BonusGll ~_,a.;.;:'I.~~...\o....,..-~",~.._...~ Closing Date: September 6, 2006 Previous Balance Payments And Credits Purchases Cash Advances Balance Transfers Opening Cashback Bonus Balance New Cash back Bonus Earned Cash back Bonus Balance Available to Redeem $ + 4.57 0.00 4.57 0.00 $ $ Cashback Bonuse Anniversary Date: August 6 How Can We Help You? Please haw your Discover Card ava~able. Manage your account online at Discowrcard.com Customer Service: 1-8()()"DISCOVER (1-8()()"347-2683) For Account Inquiries, write to u. at: Discover Card, PO Box 30943 Salt lake City, UT 84130 TOO (Telecommunications Device for the Deaij: For assistance, see reverse side. Transactions Other/Miscellaneous So Fraud Uability Guarantee Use your Discover Card with conFidence. T ran.. Post Date Date Sep 6 Sep 6 OVERUMIT FEE Sep 6 Sep 6 LATE FEE $ 39.00 39.00 'Information For You The address provided in your Cardmember Agreement to request a beneficiary designation form for your Scheduled Air Travel Accident Insurance has changed. The new address is AIG Accident & Health Division, 300 South Riverside Plaza, 'Suite 2100, Chicago, Illinois 60606-6613. While we are permitted under the Cardmember Agreement to increase the APRs on your Account because your payment was late, we have chosen not to do so at this time. We have terminated, however, any introductory or promotional rate on purchases and any special balance transfer rate, and applied the standard APR for purchases to your outstanding balance of purchases and balance transfers. However, we reserve the right to increase the APRs on your Account if you fail to pay the minimum payment due by the payment due date. See the Default Rate Plan section of the Cardmember Agreement for details. VERIFICA nON The undersigned does hereby verify subject to the penalties of 18 P A.C.S. 94904 relating to unsworn falsifications to authorities, that he is Accounts Manager (Title) Robert Adkins. (Name) of Discover Financial Services. LLC., plaintiff herein, that (Company) he 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# 5570214 HEATHER L COOK 6011002170674022 ~ ~ -- ~ ~ ~ Vl !11 ~ C> (:) \ '-.J ('- ('- :S :cJ ~ ~ J:- r", r~ c~ 0- :c Zj o [".', C) r.....' v' _; (:C c-.., .:_---:.~;,'n ':-i:~ U1 ~D cr't --< ~_r" ,. , IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff No. : 06-7277 CIVIL TERM vs. PRAECIPE TO SETTLE, DISCONTINUE AND END WITHOUT PREJUDICE TO REFILE HEATHER L COOK Defendant FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: JAMES C. WARMBRODT PA I.D #42524 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05570214 ../ IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff vs. Civil Action No. : 06-7277 CIVIL TERM HEATHER L COOK 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 L.. , / / L COMMONWEAlTH.oF P.~NNSYL VANIA Nolana\ Se;'\< . Werle)'! L G:lui\. 1'j:)taryPubllc City Of PlttopurgL;> q'~gheny County MyCommissior F.-~:)\l'jsJuIy15.2010 . t' IN t8.(19f, Member, PennsylVania Assocla lor, 0 . 0 SWORN TO AND SUBSCRIBED d;)~ay f-.) = = -.J. 3 ~u ::::0 I \.0 o ." ~." nl- F.; -Ot..i-'l --J C.j ~}~ ~;i~ S::?; ?O =-< 5: '7? 1"..)