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Home My WebLink About08-6609Our File No.: 186721 APOTHAKER & ASSOCIATES, P.C. 'BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff DISCOVER BANK c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. SANDRA R OKUM 1 NITA CT MECHANICSBURG, PA 17050 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 02 - UU04 0,witTen, NOTICE 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 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. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 Our File No.: 186721 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff DISCOVER BANK c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. SANDRA R OKUM I NITA CT MECHANICSBURG, PA 17050 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: ?tv, 6 k- ({ 6 0 4 &nil '7z-z--- CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is DISCOVER BANK c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are SANDRA R OKUM, an adult individual residing at 1 NITA CT MECHANICSBURG, PA 17050. 3. At the special instance and request of Defendant, Plaintiff, DISCOVER BANK, issued to Defendant(s), Account #6011002590835237. 4. Defendant received, accepted and used the account to its benefit. 5. This account is in default and Defendant(s) has an unpaid balance of $4,119.37. A true and correct copy of the total due and owing is attached hereto, made a part hereof and marked as Exhibit "A". 6. All credits, if any, to which Defendant(s) is entitled, have been applied to the account and are included in Exhibit "A". 7. Although demand has been made, Defendant(s) has failed to make payment of the amount due as above. ti WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of '$4,119.37 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & AS C TES, P.C. Attorney f Pl ' tiff A Law Firm EnaaJ in bt Collectio BY: David I ApothkW Esquire Dated: 10/31/2008 Our File No.: 186721 VERIFICATION David J. Apothaker, Esquire, Esq. hereby states that I am counsel for plaintiff in this action, and that I am authorized to take this Verification, and that the statements made in the foregoing Civil Action Complaint are true and correct to the best of my knowledge, information, and bflief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A.A904 relating to David J. Apothaker, Esquire Attorney for Plaintiff ification to authorities. DATE: 10/31/2008 SANDRA R OKUM 1 NITA CT MECHANICSBURG, PA 17050 STATEMENT OF ACCOUNT DISCOVER BANK Debtor's Name: SANDRA R OKUM Account Number: 6011002590835237 Balance Due: $4,119.37 Our File No.: 186721 EXHIBIT "A" 0 0 V1 v! r rn In the Common Pleas Court of Cumberland County State of Pennsylvania Plaintiff. Discover Bank Case Number: 08-6609 C/O Apothaker & Associates, PC 520 Fellowship Road C 306 Mount Laurel, NJ 08054 Vs. Defendant: Sandra Okum 1 Nita Court Mechanicsburg, PA 17050 ANSWER TO COMPLAINT In 2007 my husband, Ronald Okum, was laid off from his job for about 6 months before finding another job. During this time I was able to pay my bills and on time. Since his new job paid significantly less than his previous job it was getting more difficult to keep up with the bills and make timely payments. I was forced to "rob Peter to pay Paul". However, then interest rates and the payments requested went a lot higher. I did my best but finally had to resort to Freedom Debt Relief to handle the account. I am trying to avoid bankruptcy. Generally I disagree with the attorney fees and court costs. Respectfully submitted, CERTIFICATE OF SERVICE I, the undersigned, hereby certify that I have served the Plaintiff or its attorney with a copy of this pleading by US mail, postage pre-paid, on this 6t` day of December, 2008. 4k4_? ckc? D FENDANT -c co 4jt 75 SHERIFF'S RETURN - REGULAR CASE NO: 2008-06609 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS OKUM SANDRA R MARK CONKLIN Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon OKUM SANDRA R the DEFENDANT at 0020:55 HOURS, on the 20th day of November-, 2008 at 1 NITA COURT MECHANICSBURG, PA 17050 by handing to SANDRA OKUM DEFENDANT a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 Service 10.00 oe, ??4 Affidavit .00 Surcharge 10.00 R. `'Thomas Kline 00 38.00 11/24/2008 APOTHAKER & ASSOCIATES Sworn and Subscibed to By: before me this day Deputy heriff of A.D. Defendant. 0 Our file No.: 186721 APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff Attorney ID# 55140 DISCOVER BANK Plaintiff, VS. SANDRA R OKUM C C G j"I" ?u DEC P. 2 ?a08 By COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 08-6609 Civil Action STIPULATION IN LIEU OF JUDGMENT The matters and things in controversy having been discussed by and between the parties, and a settlement having been agreed upon: It is on December 12, 2008, STIPULATED by and between Plaintiff, DISCOVER BANK, and Defendant, SANDRA R OKUM parties as follows: 1. Defendant agrees to pay the sum of $4,297.87, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. The sum aforesaid of $4,297.87 shall be paid by the by Defendant, SANDRA R OKUM, to the attorneys for Plaintiff in the following manner: a. $700.00 to be paid on or before December 23, 2008; b. $405.87 to be paid on or before January 23, 2009; c. $114.00 to be paid on or before the 23`d day of each month, beginning February 23, 2009 until paid in full. All checks are to made payable to DISCOVER BANK, and sent to: Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 3. In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation, then, and in that event, Plaintiff shall be entitled to obtain the entry of Judgment against Defendant ex parte, in the sum of $4,297.87, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. Jr 4. In the event of default as aforesaid, and default is not cured within ten (10) days, Plaintiff shall be entitled to obtain the entry of Judgment upon ex parte application, with supporting certification, and with notice to Defendant only in the form of a copy of the application addressed to SANDRA R OKUM by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES, P.C. A Law Firm Engagedjpbt Collection Scian, Esquire JJA_k? K Oht?/nl> SANDRA R OKUM C) 7 F7 ?•?r, {v_ : ? r n Our File No.: 186721 APOTHAKER & ASSOCIATES, P.C. BY: Kimberly F. Scian, Esquire Attorney I.D.# 55140 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff DISCOVER BANK COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, vs. SANDRA R OKUM NO. 08-6609 Defendant. PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. Dated: June 11, 2009 APOTHAKER & ASSOCIATES, P.C. Attorneys for Plaintiff A Law Firm Engaged in Debt Collection OF THE P ";,CRY 2009 JUN 15 F 3* 3 b CLAP ;',