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Home My WebLink About03-5656Our File No. 167345 ATTORNEYS FOR PLAINTIFF E~IC Mo 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 DISCOVER BANK c/o ERIC M. BERMAN, P.C. 198 Allendale Road, Suite 306 King of Prussia, PA 19406 VS. COURT OF COMMON PT~AS COUNTY OF CUMBERLAND TRIAL DIVISION CIVIL ACTION Term ALYSSA A SHAPIRO 6107 LOCUST LN MECHANICSBURG, PA 17050 7335 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 againet you. You are warned that if you fail to do eo 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. 167345 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 DISCOVER BANK c/o ERIC M. BERMAN, P.C. 198 Allendale Road, Suite 306 King of Prussia, PA 19406 VS. ALYSSA A SHAPIRO 6107 LOCUST LN MECHANICSBURG, PA 17050 7335 COURT OF COMMON P~AS COUNTY OF CUMBERLAND CIVIL ACTION Term COMPLAINT 1. Plaintiff, DISCOVER BANK , 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), ALYSSA A SHAPIRO , resides at 6107 LOCUST LN , MECHANICSBURG, PA 17050-7335. 3. There is due from the Defendant(s) the sum of $2,678.97 for credit extended by Plaintiff to Defendant(s), acct. no. 6011002010626513, 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 $2,678.97 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. Ail applicable credits, if any, have been duly applied to Defendant(s) credit account. WHEREFORE, Plaintiff claims of the Defendant(s) the sum of $2,678.97 plus interest, attorneys fees and costs which are justly due and owing from the Defendant(s) to the Plaintiff. Dated: OCTOBER 13, 2003 ERIC M~ERMAN, P.C. BY:ERI~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 18 Pa C.S.A. Section 4904 relating to unsworn falsifications to authorities. ERIC Mo Dated: BERMAN , ESQUIR~ OCTOBER 13, 2003 ROBERT M. KLINE, ESQUIRE SPACEBNW-ZN SHERIFF'S RETURN - CASE NO: 2003-05656 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS SHAPIRO ALYSSA A REGULAR SHANNON SHERTZER , Cumberland County, Pennsylvania, says, the within COMPLAINT & NOTICE SHAPIRO ALYSSA A DEFENDANT , at 0922:00 HOURS, at 6107 LOCUST LANE MECHANICSBURG, PA 17050-7335 ALYSSA A SHAPIRO a true and attested copy of COMPLAINT Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 7th day of November , 2003 by handing to & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 6.90 Affidavit .00 Surcharge 10.00 .00 34.90 Sworn and Subscribed to before me this /F'? day of ~ [ ~u~ ,~'~.~ -I o &13 A.D. So Answers: R. Thomas Kline 11/06/2003 ERIC BERMAN By: ~eputy She r i%~ Cur File No_ ATTORNEYS FOR PLAiNTiFF FRii~ H. BERMAN, P_C. P,;f: Eric M. Barman, ~s%uire, I.D. ~y: Robert M. K]ine, ~squire,l.D. i~S Allendaie Road. Suite Kins of Rrussia~ PA 19406 (6!0} 2e5-7720 5C;47~! COURT OF COMMON PLEAS COUNTY OF CUMBERLAND SCOVER BANK ERIC'M. BERMAN. P.C. : TRIAL DIVISION 198 A!lendale Road~ Suite S06 : CIVIL ACTION King of Prussia. PA 19406 vs. : No. 2003-05656 ALYSSA A SHAPIRO ALYSSA A SHAPIRO 6107 LOCUST LN MECHANICSBURG, PA 17050-7885 TO: NOTICE Pursoant to R~,31e 23L% of the Supreme Court of Pennsylvania, yo~_; are hereby notified that a JUDGMENT BY DEFAULT has been entered against you in the above proceeding and that enclosed herewith is a copy of all the (record} documents filed in support of the said JUDGMENT. !F YOU HAVE ANY 'eUESTIONS CONCERNING THIS NOTICE, PLEASE CAI,L: ERIC M_ BEPMAN, P.C.? Attorneys at Law. Attention: Eric M. Berman, Esquire, or Robert M. Ktine, Es%!uire. at this telephone number. 1-61()-2~;5-.7720. PROTHONOTA~2' ODURT OF COMMON PLEAS COUNTY OF CUMBEY~LAND i)T SCOVER SAN'..( ~/e ERIC M. BEiffAN, P.C. 19~ Ai!enda!e Road, Suit:e 306 King ~.~f Pr~.:s~a, PA 09406 V S . AL~io,;A A SHAPi RO TRIAL Dv'a~CTn~ TO ENTER DEFAULT ..... P~MENT TO THE PROTHONOTARY: Please enter a default judgmer:t ir, favor of Plaintiff? =' T eF'¢~w~n' BANK and against Defendant, ALYo~,A A SHA}t~_. for failure to answer or otherwise respond te the Complaint -- Civil Action. The Complaint was'~ter- ",zed upon Defendant ,~n_ !!,/07/2008. t.l~e .:hera ff'~ Office of COUNTY OF CLIMBERLAND Ccunty. A copy ,of the Notice of Intentio~ NO Take i)efault serw~d upon the I)efendant by regular mail on Is attached hereto as ~.,;h!o~t ~. i certify that written notice of the intention to file this Praecipe was mailed or de]ivaped to the party against whom judgment is to be entered after the default c. ccurred and at least ten days prior to the date of the filln~ of this Praecipe. Copies are attached. ~.C.P.257.~. Assess damages in the principal amount of $2,678.97, the aglOuI!t demanded in the Comp]ahlt,~ ERiC M. BERMAN, P.C. Attorneys for Plaintiff By: Eric PI. Berman, Esquire qn~ether with ..... t,,.~,~ .... tees ERi~ M BERMAN, P.C. Attorneys for Plaintiff By: Robert M. l{line, Es,%uire 2': i';:~: M. Berma~ Esquire, I.D. 83698 }7~: Re, bern M. ](lin,~, Esquire,I.D. 56479 L. zg cz Prussia, FA 12406 ~t~O'. 2f;5-7720 IISCCVER BANK c,c ERIC M. BFRMAN, P.O. .l$g Atlendale Road, Suite 212 : Sing of Pru~s:[a, f'A 194!1)8 SHAPIRO COURT OF COMMON PLEAS COUNTY OF CUMBERLAND TRIAL DIVI,:,IO, t CIVIL At. ION No. .'"OC.,J'-. 05656 NOTI ~E OF INTENTION TO TAKE DEFAULT JUD(~MEN~ IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU-HAVE FAIiLED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE ~.URg YOUR DEFENSES (DR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. JNLESS YOU ACT WITHIN TEN DAyS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO ~)UR LAWYER AT ONCE. IF DO NOT HAVE A LAWYER~ GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER, IF YOU CANNOT AFFORFD TO HIRE A LAWYEIt, THIS OFFICE MAY BE ABLE TO PROVII)E YOU WITH INFORMATION ABOUT AGENCIES THAT MAYCJFFER LEGAl.. oER~I ,,Eo TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. COUNTY OF CUMBERLAND BAR A~oO.,IATION 2 LIBERTY ~VE. CARLISLE, P~ 17013 800-990-9108 ERIC M. BEPMAN, P.C. Attorneys for Plaintiff By: Eric M. Berman, Esquire ERIC M. BERMAN, P.C. At, torneys for Plaintiff By: Robert M. Kline~ Esquire SPACEJUD- ZH Our File No. 167345 ATTORNEYS FOR PLAINTIFF ERIC M. BERMAN~ P.C. By: Eric By': Robert M. Kline, Escjuire,I.D_ I!98 A!!endale Road, Suite 806 King of Prussia~ PA DISCOVER BANK e/o ERiC M. BE~MAN, P_C. 196' Alienda!e Road, Suite Kin~ of Prussia, PA 19406 ' 'q'~ SHAP!RO ALY ,_ oA A C, OURT OF COMMON PLEAS i ?UNTY OF CUMBERLAND TRIAL DIVISION '~,~L AFTiON CERTIFICATION OF NON-MiLiTARY .... ~"~ i am one of Plaintiff's attorneys and am authorized this certifieatien cn Plaintiff's behaif. The above named Defendant(s) is (are) over. !8 years of ale and reside a.t hz,3?_ LOCUST LN , MECHANiCSBURG, PA ~,~a'~, .).~.(_ 7335. The occupation of the Defendant(s) is (are) unknown. The Defendant(s~ is (are) not in the Military Service of the United States~ nor any State or Terri'sory thereof or its allies as defined in the Soldiers' and Sailors' Civil Relief Act of I!~40 and the amendments thereto. I verify that the statements made in the foregoing ce_~-tifioation are true and correct to the best of n]y ]~nowledge, information and belief, and I understand that the statemep, ts in said certific_~tion are made subject te tile penalties of Pa.C~S. 4804 relating to unsworn falsification to autho:~itJes_ ATTORNEY FOR PLA I NTi FF SPACEJUB-ZK ROBERT M. KLINE, ATTORNEY FOR r ~AI:~ '- ~FF ATTORNEYS FOR P[~INTiFF ERiC M. BERH~N, BY: Eric M. Berman, Esquire, BY: Robert M. K!ine, Esquire. I.D. 5{~47 ~8~ Allendale Road, Suite King of Prussia~ PA (6'I0) 26~5-7720 i;OURT OF COMMON PLEAS COUNTY OF CUMBERLAND DISCOVER BANK ,?,,': ERiC M. BF. RMAN, P.C. l~ A]iendate Road Suite ALYSSA A SHAPIRO TRIAL DIVISION CIVIL ACTION ..ER ~ I F ~ u. AT It N 0 F ADDRE,~oE,J TO THE PROTHONOTARY: The address of tile Ptaintif£, Judgment Creditor, Eric b~. ~erman, P.t..: ]~8 All~ndale noad, ou~te .:k){~, King ,'Df The last known address.of the Defend,ant, Judgment Debtor, is ..~ ~' ~ ~' PA 17050 ~':'~ 6107 LC, I~ST LN , M~t,HAN~t,oBURe, . , ........ .. Erie M. Berman, P .... Attorneys for Plaintiff c,y. Eric M. Berman, Eric M. Berman. P.3 Attorneys for Plaintiff ~,y. Robert M_ Kline, Esquire