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Home My WebLink About03-6242...... ~ ..... MAN · ]?~:~:Ez'ic [-J. Berman, ~i~quire, ~Y: R~oert M. Kline, Esquire,I.D. 56479 ~'.[~8All_.nua~.e Road, Suite Eing off Prus:~ia, PA 13436 c/o ER~., M. BEGAN, P.C. 198 Allendale ~oad, Suite King of Prussia, PA 19406 COURT OF COMMON PLEAS COUNTY OF CUMBERLAND : TRIAL DIVISION ~06 : : CIVIL ACTION Tepm DOROTHY A SHOVER HAROLD R SHOVER 156 COTTAGE RD SHIPPENSBURG, PA 17257 8758 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 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 this complaint or for any other claim or relief required 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 [~) NOT HAVE A LAWYER (DR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW TO FIND {)UT WHERE YOU CAN GET LEGAL HELP. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO MIRE A LAWYER, THIS <_FFIt, E MAY BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT A(=EN(~IEo THAT MAY f~SER LEGAL oERVIOE,~ TO ELIGIBLE PERSONS AT A RED[fED FEE OR NO FEE. LAWYER REFERENCE SERVICE COUNTY {DF CUMBERLAND BAR ASSOCIATION 2 LIBERTY AVE- CARLISLE, PA 1701;~ 800-990-9108 Oar File No. 178851 ATTORNEYS FOR PLAINTIFF ERIC M. BERMAN, P.C. BY: Eric M. Berman, Esquire, I.D. 83698 BY: Robert M. Kiine, Esquire,I.D. 5f3479 19~ Allendale Road, Suite :306 King of Prussia, PA 1940(3 (610) 2(35-7720 D I :~]COVER BANK c/o ERIC M. BERMAN, P.C. : 198 Allendale Road, Suite 306 : King of Prussia, PA 19406 : DOROTHY A SHOVER HAROLD R SHOVER 156 COTTAGE RD SHIPPENSBURG, PA 17257 8758 COURT OF COMMON PLEAS COUNTY OF CUMBERLAND CIVIL ACTION Term No. COMP LA I NT 1. Plaintiff, DISCOVER BANK , is a DELAWARE STATE BANK authorized to do business in the Co~nonwealth of Pennsylvania with its place of business at 3:311 MILL MEADOW DRIVE, HILLIARD, OH 4~028. ~. The Defendant(s), DOROTHY A SHOVER resides at 156 COTTAGE RD , SHIPPENSBURG, PA HAROLD R SHOVER 17257-8758. ;3. There is due from the Defendant(s) the sum of $2,605.76 for credit extended by Plaintiff to Defendant(s), acct. no. 6011002560556102, and which such credit was drawn and used by the Defendant(s). Defendant(e) is in default for failure to make payments for such use. 4. The Plaintiff has made demand upon the Defendant(s) for payment of monies in the sum of $2,605.76 advanced to Defendant(s) through Defendant(s) use of the above-referenced credit account, but Defendant(s) has failed and refused to pay the said sum or any part thereof. 5_ All applicable credits, if any, have been duly applied to Defendant(s) credit account. WHEREFORE, Plaintiff claims of the Defendant(s) the sum of plus interest, attorneys fees and costs which are justly due and owing from the Defendant(s) to the Plaintiff. Dated: OCTOBER 17, 2(: 03 ERIC M. P .... BY: ~ ERIC ~, ESQUIRE BY: RJBERT M. KLINE ESQUIRE SPACEBNW-ZN Attorneys for Plaintiff VERI FI CATI ON Eric M_ Berman, Esquire, being duly sworn according to law, deposes and says that he is the Principal attorney of Eric M. Berman, P.C_, attorneys for the Plaintiff, and/or Robert M_ Kline, Esquire, being duly sworn according to law.. deposes and says that he is an associate attorney with said firm, and as said attorney, is authorized to take this verification on its behalf, and that the facts in the Complaint as set forth therein are true and correct to the best, of his knowledge, information and belief. i verify that the statements made in the within instrument are true and correct. I understand that, false statements are subject to the penalties of 18 Pa C.S.A. Section 4904 relating to unsworn falsifications to authorities. ERI ~, SQU I RE Dated: OCTOBER 17, 2003 ROBERT M. KLINE, ESQUIRE SPACEBNW- ZN ~.'~-~.~ SHERIFF'S CASE NO: 2003-06242 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS SHOVER DOROTHY A ET AL ROBERT BITNER Cumberland County, Pennsylvania, says, the within NOTICE SHOVER DOROTHY A DEFENDANT , at 0015:59 HOURS, at 156 COTTAGE RD SHIPPENSBURG, PA 17257 DOROTHY SHOVER a true and attested copy of NOTICE COMPLJtINT RETURN - REGULAR Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 3rd day of December , 2003 by handing to together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 14.49 Affidavit .00 Surcharge 10.00 .00 42.49 Sworn and Subscribed to before me this %0 --' day of ot~onotary ' So Answers: R. Thomas Kline 12/04/2003 ERIC BERMAN / Deputy Sheriff SHERIFF'S RETURN - CASE NO: 2003-06242 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS SHOVER DOROTHY A ET AL REGULAR ROBERT BITNER Cumberland County, Pennsylvania, says, the within NOTICE SHOVER HAROLD R DEFENDANT at 0015:59 HOURS, at 156 COTTAGE RD SHIPPENSBURG, PA 17257 DOROTHY SHOVER (WIFE) a true and attested copy of NOTICE COMPLAINT Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 3rd day of December , 2003 by handing to together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 6 Service Affidavit Surcharge 10 16 O0 O0 O0 O0 O0 O0 Sworn and Subscribed to before me this /~ day of ~ ~.~ ~ ~Z~3 A.D. honotary ' ' ' So Answers: R. Thomas Kline 12/04/2003 ERIC BERMAN ~eputy Sherizz