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Home My WebLink About08-6610Our File No.: 186730 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. RODNEY S PIFER 112 BIG SPRING TER NEWVILLE, PA 17241-9111 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY og - Wto Civit lir+k 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.: 186730 ` 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. RODNEY S PIFER 112 BIG SPRING TER NEWVILLE, PA 17241-9111 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: D G L t D,f l ..•?- 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 RODNEY S PIFER, an adult individual residing at 112 BIG SPRING TER NEWVILLE, PA 17241-9111. 3. At the special instance and request of Defendant, Plaintiff, DISCOVER BANK, issued to Defendant(s), Account #6011002370392375. 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 $8,554.17. 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. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $8,554.17 and requests this Court award Plaintiff attorney's fAs and costs to the extent permitted by applicable law. APOTHAKER Attorn A Law Firm Eni BY: David J. ASS IATES, P.C. for laintiff ed ' Debt lectiol )thaker, Esquire Dated: 10/30/2008 Our File No.: 186730 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, therein are made subject to the penalties of 18 belief. The undersigned understands that the statements relating to unsworn falsification to authorities. Apothaker, Esquire bev for Plaintiff DATE: 10/30/2008 DISCOVER BANK RODNEY S PIFER 112 BIG SPRING TER NEWVILLE, PA 17241-9111 STATEMENT OF ACCOUNT Debtor's Name: RODNEY S PIFER Account Number: 6011002370392375 Balance Due: $8,554.17 Our File No.: 186730 EXHIBIT "A" ? 1 3 .? -c d ?s? SHERIFF'S RETURN - REGULAR CASE NO: 2008-06610 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS PIFER RODNEY S KENNETH E GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon PIFER RODNEY S the DEFENDANT , at 0013:35 S, on the 17th day of November , 2008 at 112 BIG SPRING TERRACE NEWVILLE, PA 17241 by handing to RODNEY PIFER DEFENDANT 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: So Answers: Docketing 18.00 Service 061 00' Affidavit .00 ::?e ?W? Surcharge 10.00 R. Thomas Kline 00 40.00 11/18/2008 APOTHAKER & ASSOCIATES Sworn and Subscibed to By: before me this day of A.D. Our File No.: 186730 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff DISCOVER BANK COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, vs. RODNEY S PIFER NO. 08-6610 Defendant. PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER AttornA Law Firm E By: David J. A SOCIATES, P.C. Plaintiff in Debt Cc116ctioi , Esquire Dated: February 13, 2009 c'? ev ?.._. a ,., ?} -?, r ~ .? • ; ., { ? ?, r;- -: i_ .:_. ?-- _.:. ?. ':: Y _,?, ?