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Home My WebLink About03-6425Our File No_ 180609 ATTORNEYS FOR PLAINTIFF ERIC M_ BERMAN, P.C. BY: Eric M. Berman, Esquire, I.D. 83698 BY: Robert M. Kline, Esquire,I.D. 56479 198 Allendale Road, Suite 306 King of Prussia, PA 19406 (610) 265-7720 -----------------------------------------x DISCOVER BANK c/o ERIC M_ BERMAN, P.C_ 198 Allendale Road, Suite 306 King of Prussia, PA 19406 vs_ TIM J PANAGOS 100 E KING ST SHIPPENSBURG, PA 17257 1326 COURT OF COMMON PLEAS COUNTY OF CUMBERLAND TRIAL DIVISION CIVIL ACTION Term x No. 03 -10 c/'?S Crv?C , 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 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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 REFERENCE SERVICE COUNTY OF CUMBERLAND BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PA 17013 800-990-9108 Our File No. 180609 ATTORNEYS FOR PLAINTIFF ERIC M_ BERMAN, P.C. BY: Eric M. Berman, Esquire, I.D. 83698 BY_ Robert M_ Kline, Esquire,I.D. 56479 198 Allendale Road, Suite 306 King of Prussia, PA 19406 (610) 265-7720 -----------------------------------------X DISCOVER BANK c/o ERIC M. BERMAN, P.C. 198 Allendale Road, Suite 306 King of Prussia, PA 19406 vs. TIM J PANAGOS 100 E KING ST SHIPPENSBURG, PA 17257 1326 ----------------------------------------- COMPLAINT 1. Plaintiff, DISCOVER BANK , COURT OF COMMON PLEAS COUNTY OF CUMBERLAND CIVIL ACTION Term No _ 03 - (a;? is a DELAWARE STATE BANK authorized to do business in the Commonwealth of Pennsylvania with its place of business at 3311 MILL MEADOW DRIVE, HILLIARD, OH 43026. 2. The Defendant(s), TIM J PANAGOS , resides at 100 E KING ST , SHIPPENSBURG, PA 17257-1326. 3. There is due from the Defendant(s) the sum of $6,736.69 for credit extended by Plaintiff to Defendant(s), acct. no. 6011002520108663, and which such credit was drawn and used by the Defendant(s). Defendant(s) 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 $6,736.69 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 $6,736.69 plus interest, attorneys fees and costs which are justly due and owing from the Defendant(s) to the Plaintiff. Dated_ OCTOBER 26, 2003 ERIC M. B ;N, P.C. BY. ERIC M. AN ESQUIRE BY: ROBERT M. KLINE ESQUIRE SPACEBNW-ZN Attorneys for Plaintiff VERIFICATION 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 16 Pa C.S.A. Section 4904 relating to unsworn falsifications to authorities. 0/1 Z /N ? 1111??A ERIC M. BERMAN, ESQUIRE ROBERT M. KLINE, ESQUIRE Dated: OCTOBER 26, 2003 SPACEBNW-ZN tj:- '69 a C7 c SHERIFF'S RETURN - REGULAR CASE NO: 2003-06425 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS PANAGOS TIM J CPL. TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PANAGOS TIM J the DEFENDANT , at 1800:00 HOURS, on the 6th day of January 2004 at 100 E KING ST SHIPPENSBURG, PA 17257-1326 by handing to TIM J PANAGOS 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 14.49 Affidavit .00 Surcharge 10.00 .00 42.49 Sworn and Subscribed to before me this 13 day of /l ly- Ujrri? `f A.D. 1 1P24othonotary So Answers: R. Thomas Kline 01/07/2004 ERIC BERMAN i?y1 l By: Deputy Sherif IN THE COURT OF COMMON PLEAS OF CUMBELRAND COUNTY - PENNSYLVANIA DISCOVER BANK : No. 03-6425 C/o Eric M. Berman, P.C. 198 Allendale Road, Suite 306 : Civil Action - Law King of Prussia, PA 19406 Plaintiffs: vs Tim J. Panagos 100 E. King Street Shippensburg, PA 17257 Defendant Trial Division ANSWER Now come the Defendant, Tim J. Panagos, by and through their Attorney, H. Anthony Adams, and set forth the following: 1. Admitted 2. Admitted 3. Denied, after reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of the matter averred. 4. Denied, after reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of the matter averred. 5. Denied, after reasonable investigation Defendant is without knowledge or information sufficient to form a belief as to the truth of the matter averred. Wherefore, Defendant prays your Honorable Court dismiss the complaint of Plaintiff. Respectfully submitted, H. Anthony Adams, Esquire Attorney for Defendant 49 W. Orange Street, Suite 3 Shippensburg, PA 17257 (717)-532-3270 VERIFICATION I verify that the statements made in this answer are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. I _? Date: ?/ f7 0 (y7 r VJ Rl? rn N J Our File No. 180609 ERIC M. BERMAN, P.C. By: Robert M. Kline, Esquire Atty. ID.No. 56479 500 North Gulph Road, Suite 350 King of Prussia, PA 19406 (484) 690-3980 DISCOVER BANK : VS. TIM J. PANAGOS Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION No. 03-6425 STATEMENT OF INTENTION TO PROCEED TO THE PROTHONOTARY: Kindly mark the docket to reflect that Plaintiff, Discover Bank desires to proceed with this matter. Robert M. Kline, Esquire Attorney for Plaintiff Dated: October 31, 2007 c ? !T cz) f7w d go ?