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Home My WebLink About06-7278IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. DEBRA A SCOTT Defendant No : CG- - '7.2-7U 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 05500370 C A Pit WLG IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No DEBRA A SCOTT 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 6500 NEW ALBANY ROAD NEW ALBANY , OH 43054 2. Defendant is adult individual(s) residing at the address listed below: DEBRA A SCOTT 503 W MARBLE ST MECHANICSBURG, PA 17055 3. Defendant applied for and received a credit card issued by Plaintiff bearing the account number 6011002250515285 . 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 14, 2006 , in the amount of $6497.45 . 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 , DEBRA A SCOTT INDIVIDUALLY , in the amount of $6497.45 with interest at the legal rate of 6.0009. per annum from date of judgment plus attorneys' fees of $1000.00 , and costs. Jame Warmbrodt,42524 WEL , WEINBERG & REIS CO., L.P.A. 436 Se enth Avenue, Suite 2718 Pi tsb rgh, PA 15219 ( 12) 434-7955 F 12-338-7130 550 370 C A Pit WLG This law firm is a debt collector a tehpting to collect this debt for our client and any information obta ed will be used for that purpose. V E R $6,497.45 - - - -- - $795.00 enter amount enclosed below CARD payment due date .? September 26, 2006 Please make check payable to Discover Card. You are overlimit. Pay the sum of the monthly minimum payment plus the overlimit amount of $1,097.45. 27 SDSN6A01 0002944 DEBRA SCOTT Consolidate bills quickly and securely 128 W PORTLAND ST APT 6 with a Balance Transfer to your Discover Card - Call 1-877-353-0989 or visit MECHANICSBURG PA 17055-7415 Discovercard.com/balancetransferTODAYI PO BOX 15251 111119111111111 11 1111111111 WILMINGTON DE 19886-5251 Address, e-mail or telephone change? Print change in space above, or ' I I I I I' I () I I I I I I 'III ' i go to Discovercwd. com. Print your e-mail address to receive Important Account information and special offers. 000006011002250515285064974500000000079500 Discover Card Account Summary account number payment due date minimum payment due credit limit credit available cash credit limit cash credit available 6011 0022 5051 5285 September 26, 2006 $795.00 $5,400.00 $-1,097.00 $2,700.00 $0.00 V17 - Closing Date: August 27, 2006 page 1 of 2 previous balance $6,290.78 payments and credits - 0.00 purchases + 78.00 cash advances + 0.00 balance transfers + 0.00 FINANCE CHARGES + 128,67 new balance = $6,497.45 EXHIBIT You maybe able to avoid Periodic Finance Charges, see the reverse side for details. .A Cashback Bonus® Cashback Bonus® Anniversary Date: November 27 Opening Cashback Bonus Balance $ 0.00 New Cashback Bonus Earned + 0.00 Cashback Bonus Balance $ 0.00 Available to Redeem $ 0.00 Transactions trans. post date date Other/Mlscellaneous Aug 27 Aug 27 OVERLIMIT FEE Aug 27 Aug 27 LATE FEE $ 39.00 39.00 While we are permitted under the Cardmember Agreement to increasethe 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. ******* ATTENTION ******* ATTENTION *****,* ATTENTION ******* ATTENTION ******* ATTENTION RRRRRRR Your account is seriously past due. Payment of the amount due and arranaamanta for fuhurn nAVmAntc ehnutrl ha VERIFICATION The undersigned does hereby verify subject to the penalties of 18 PA.C.S. §4904 relating to unsworn falsifications to authorities, that he is Robert Adkins, (Name) Accounts Manager of Discover Financial Services, LLC., plaintiff herein, that (Title) (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. ( ignature) WWR # 5500370 DEBRA A SCOTT 6011002250515285 r-? ^.,? ?? ?? ? CJ ?` ?. T ? ? ? ,,{ ?, ?.> C'? ? ? D _? -r3 f t ?.7 Cd> :? ??, --? tai: a_? _ i.?; -- `? - ^ '3 r+? (/, ?.? J ...? i s IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. DEBRA A SCOTT Defendant No.: 06-7278 CIVIL TERM PRAECIPE TO REINSTATE COMPLAINT FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: William T. Molczan, Esquire PA I.D. #47437 WELTMAN, WEINBERG & REIS, CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05500370 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No.: 06-7278 CIVIL TERM DEBRA A SCOTT Defendant PRAECIPE TO REINSTATE COMPLAINT Kindly reinstate the Complaint in the above captioned matter. WELTMAN, WEINBERG & REIS CO., L.P.A. By: William T. Mo czan, Esq e PA I.D. 447437 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR #05500370 N N top e c IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. DEBRA A SCOTT Defendant No. 06-7278 CIVIL TERM PRAECIPE TO SETTLE, DISCONTINUE AND END FILED ON BEHALF OF Plaintiff COUNSEL OF RECORD OF THIS PARTY: PATRICK THOMAS WOODMAN, ESQUIRE PA I.D #34507 V!ELTMAN, WEINBERG & RE!S CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05500370 IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL DIVISION DISCOVER BANK Plaintiff VS. Civil Action No. 06-7278 CIVIL TERM DEBRA A SCOTT Defendant PRAECIPE TO SETTLE DISCONTINUE AND END TO THE PROTHONOTARY OF COUNTY: Settle, Discontinue and End the above-captioned matter upon the records of the Court and mark the costs paid. WELTMAN, WEINBERG & REIS CO., L.P.A. By:c•?ao PATRICK THOMAS WOODMAN, ESQUIRE PA 1.1 3,434507 WELTMAN, WEINBERG & REIS CO., L.P.A. 2718 Koppers Building 436 Seventh Avenue Pittsburgh, PA 15219 (412) 434-7955 WWR#05500370 Sworn to and Before me the Day-of MAY, y Notarial se'll Wayne A. Jones, Notary Public City Of Pinsbtso, Allegheny County My Commission E)*es Juna 29, 2010 Member, Pennsylvania Association of Notaries - a C? t t?. ..? ? r; -? ,. -- ?r ? , ; ?-.- ?- r;,, _::` ; ? ? ?. ???, .r :-G ' ,? SHERIFF'S RETURN - REGULAR CASE NO: 2006-07278 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS SCOTT DEBRA A RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon SCOTT DEBRA A the DEFENDANT at 1550:00 HOURS, on the 12th day of March 2007 at 503 W MARBLE STREET MECHANICSBURG, PA 17055 by handing to LEE ROGERS, BOYFRIEND, ADULT IN CHARGE a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 67.20 Affidavit .00 Surcharge 10.00 .00 3) V' 95.20 131- Sworn and Subscibed to before me this day of , So Answers: R. Thomas Kline 03/13/2007 WELTMAN WEINBERG REIS By: Deputy Sheriff A. D.