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Home My WebLink About04-1311STOCK & GRIMES, TLP BY: EDWARD STOCK, ESOUIRE I.D.# 13657 804 West Avenue Jerlkintown, PA 19046 (215) 576-1900 Attorney for Plaintiff MARLYN FINANCIAL SERVICES, LLC, ASSIGNEE OF DISCOVER 'FINANCIAL SERVICES,INC. c/o Edward Stock, Esquire 804 West Avenue Jenkintown, PA 19046 Plaintiff COURT OF COMMON ?LEAS C~RLZ~MD COUNTY CIVIL ACTiON-LAW HEATHER MERRIS Apartment 2 215 N. 2nd Street Lemoyne, PA 17043-1102 Defendant(s) "NOTICE" "You have been sued in court. II you wish to'defend against the claims set lorth in the fol- lowing pages, you must take action within twenty (g0) days after this complaint and notice are served, by entering a written appdarance person- ally or by attorney and filing in writing with the court your defenses or obiactions to the claims sel forth against you. You are warned that-if you fail to do so the case may proceed without you and a iudgment 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. "Lehan demandado a usteden la corte. Si usted quiere defenderse de estas demandas ex- puestas en las p~ginas siguientes, usted tiene veinte (20) df'as de plazo al partir de la fecha de ia demanda y ia notificaci~n, Hace taJta asentar una comparencia escdta o en persona o con un abogado y entregar a la corte en forma escrita sus detensas o sus objeciones a las demandas en contra de SU persona. Sea avisado qua si usted no se defieede, ia corte Iomar~ medidas y puede continuar la demanda en contra suya sin previo awso o notificacidn. Adam&s, ia corte puede decidir a favor del demandante y requiere que usted cumpla con todas fas provisiooes de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes para "LLEVE ESTA DEMANDA A UN A~O- GADO INMEDIATAMENTE. SI NO TIENE ABO- GADO O SI NO TIENE ELDINERO SUFICtENTE DE PAGAR TAL SERVtCIO., VAYA EN PER- SONA O LLAME POR TE.L. EFONO A LA OFI- CINA GUY A DIRECCION SE ENCUENTRA ESCRfTA ABAJO ARA AVERIGUAR BONOE Court ~d~inistrator -- Cunberlan~] County Courthouse 4th Floor, One Courthouse Square Carlisle, P~ 1~0~3 (7t7) 240-6200 above caption. 4. On sundry and various occasions, Defendant(s), with the use of a (or) credit card(s~ issued by Discover Financial Services, Inc. pursuant to their credit card agreement(s), made various purchases of goods and/or merchandise with the use of the credit card(s) from authorized merchants. 5. The present outstanding balance which is due on the account(s) is $9,100.70; and, although repeated requests and demands have been made upon the Defendant(s) to satisfy the same in accordance with the terms and conditions of the credit card agreement(s), the Defendant(s) has/have and still refuse(s) to pay the same. 6. As a result thereof, Plaintiff has been forced to incur reasonable attorney collection fees in the sum of $2,275.17 in an attempt to legally enforce collection of the debt(s) due it from the Defendant or Defendants. 7. THIS COMMUNICATION IS FROM A DEBT COLLECTOR. THIS IS AN ATTEMPT TO COLLECT A DEBT AND ANY INFORMATION OBTAINED WILL BE USED FOR THAT PURPOSE. W~REFORE, Plaintiff, MarLyn Financial Services, LLC, as the assignee and/or purchaser of the credit card account(s) with Discover Financial Services, Inc,, demands Judgment against the Defendant(s), Heather Merris, in the sum of $11,375.87, with interest and costs. Attorney for Plaintiff VERIFICATION EDWARD STOCK, ESQUIRE, Attorney for Plaintiffherein, verifies that the statements made in this Pleading are true and correct and that he is authorized to make them on behalf of the Plaintiff. He understands that the statements herein are made subject to the penalties of 18 Pa. C.S.A. Sec. 4904, relating to tmswom falsification to authorities. ~ .... SHERIFF'S RETURN - CASE NO: 2004-01311 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND MARLYN FINANCIAL SERVICES LLC VS MERRIS HEATHER REGULAR VALERIE WEARY , Cumberland County, Pennsylvania, says, the within COMPLAINT & NOTICE MERRIS HEATHER DEFENDANT , at 1905:00 HOURS, at 1871 W LISBURN ROAD CARLISLE, PA 17013 STEVE MERRIS, FATHER a Sheriff or Deputy Sheriff of who being duly sworn according to law, was served upon the on the 7th day of April , 2004 by handing to 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 9.66 Affidavit .00 Surcharge 10.00 .00 37.66 Sworn and Subscribed to before me this /~ day of ~r~ 2Z-&T3 ~ A.D. /P~othonotary ' ! ' So Answers: R. Thomas Kline 04/08/2004 MARLYN FINANCIAL SERVICES By: Deputy~e~ri~j STOCK & GRIMES, LLP BY: Edward Stock, Esquire I.D.#13657 804 West Avenue Jenkintown, PA 19046 (215) 576-1900 Attorney for Plaintiff MARLYN FINANCIAL SERVICES, LLC, ASSIGNEE OF DISCOVER FINANCIAL SERVICES, INC. c/o Edward Stock, Esquire 804 West Avenue Jenkintown, PA 19046 COURT OF COMMON PLEAS CUMBERLAIqD COUNTY CIVIL ACTION-LAW NO. 2004-01311 Plaintiff vs. HEATHER E. MERRIS 1871 W. Lisburn Road Carlisle, PA 17013 Defendant (s) PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Enter Judgment by Default in favor of the Plaintiff, MarLyn Financial Services, LLC, Assignee of Discover Financial Services, Inc., and against the Defendant(s), Heather E. Merris, for failure to Answer the Civil Action Complaint. Assess Plaintiff's damages in the sum of of the Complaint. $11,375.87 in accordance with the prayer I hereby assess damages in the sum of $11,375.87 in favor of the Plaintiff, MarLyn Financial Services, LLC, Assignee of Discover Financial Services, Inc., and against the Defendant(s), Heather E. Merris, as above. PRO PROTHY AFFIDAVIT OF NON MILITARY SERVICE Edward Stock, Esquire, being duly sworn according to law, deposes and says: (a) That the Defendant(s) is/are not in the Military or Naval Service of the United States or its Allies, or otherwise within the provisions of the Soldiers' and Sailors' Civil Relief Act of Congress of 1940 as amended; (b) That Defendant, Heather E. Men'is, is approximately 40 years of age, resides at 1871 W. Lisbum Road, Carlisle, PA 17013, and is self-employed. (c) That Defendant, , is approximately 40 years of age, resides at , and is a housewife. Affiant has ascertained the foregoing information by personal investigation and makes this Affidavit in due authority; and he understands that the statements herein are made subject to the penalties of 18 Pa. C.S. Sec. 4904, relating to unswom falsification to authorities. MARLYN FINANCIAL SERVICES, LLC, ASSIGNEE OF DISCOVER FINANCIAL SERVICES, INC. Plaintiff VS. COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION-LAW HEATHER E. MERRIS NO. 04-01311 Defendant(s) CERTIFICATION UNDER PA. R.C.P. 237.1 EDWARD STOCK, ESQUIRE, Attorney for Plaintiff, MarLyn Financial Services, LLC, Assignee of Discover Financial Services, Inc., certifies that he sent a copy of the attached Notice on May 10, 2004 by regular mail, to the Defendant(s) at the address at which the Defendant(s) was/were served with a copy of the Complaint by the Office of the Sheriff of Cumberland County as indicated by the court re~s-~ DATE: ED Attorney for Plainti~-~ MARLYN FINANCIAL SERVICES, LLC, ASSIGNEE OF DISCOVER FINANCIAL SERVICES, INC. Plaintiff VS. HEATHER E. MERRIS Defendant(s) TO: Heather E. Merris 1871 W. Lisburn Road Carlisle, PA 17013 Date: May 10, 2004 COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION-LAW NO. 2004-01311 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN (10) 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 PAPER TO YOUR LAWYER AT ONCE, IF YOU 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 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. LAWYERS REFERENCE SERVICE COURT ADMINISTRATOR-CUMBERLAND COUNTY COURTHOUSE 4TM FLOOR, ONE COURTHOUSE SQUARE CARLISLE, PA 17013 (717) 240-6200~__~..~ EDWARD STOCK, ESQUIRE Attorney for Plaintiff 804 West Avenue Jenkintown, PA 19046 (215) 576-1900