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Our File No.: 179650
APOTHAKER & ASSOCIATES, P.C.
BY: David J. Apothaker, Esquire, Esq.
`Attorn6y 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.
THOMAS A PAULSON
617 HUMMEL AVE
LEMOYNE, PA 17043-1830
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: 08 • to S'1(o CiviiTe-re,
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.: 179650
APOTHAKER & ASSOCIATES, P.C.
BY: David J. Apothaker, Esquire, Esq.
`Attomby 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.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: O fr., G IR, 7G C1w 1 4"ft
THOMAS A PAULSON
617 HUMMEL AVE
LEMOYNE, PA 17043-1830
Defendant.
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 THOMAS A PAULSON, an adult individual residing at 617 HUMMEL
AVE LEMOYNE, PA 17043-1830.
3. At the special instance and request of Defendant, Plaintiff, DISCOVER BANK, issued to
Defendant(s), Account #6011002020594446.
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 $7,864.21. 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
$7,864.21 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law.
APOTHAKER & ASSO TES, P.C.
Attorney for ain ff
A Law Firm Enga-e inn t C'.nllentirn
BY:
Dated: 11/11/2008
David J. ApotfKker, Esquire
Our File No.: 179650
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 belief. The undersigned understands that the statements
therein are made subject to the penalties of 18 Pa.C.
to unworn falsification to authorities.
David J. A cer, Esquire
Attorney or Plaintiff
DATE: 11/11/2008
DISCOVER BANK
THOMAS A PAULSON
617 HUMMEL AVE
LEMOYNE, PA 17043-1830
STATEMENT OF ACCOUNT
Debtor's Name: THOMAS A PAULSON
Account Number: 6011002020594446
Balance Due: $7,864.21
Our File No.: 179650
EXHIBIT "A"
E
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... Q r
m
a"0 fl -
.
SHERIFF'S RETURN - REGULAR
CASE NO: 2008-06876 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
DISCOVER BANK
VS
PAULSON THOMAS A
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
PAULSON THOMAS A the
DEFENDANT
, at 2004:00 HOURS, on the 2nd day of December , 2008
at 617 HUMMEL AVE
LEMOYNE, PA 17043-1830
THOMAS PAULSON
by handing to
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
Service
Affidavit
Surcharge
lxw S?Gfr C?w
So Answers:
18.00
14.40
.00
10.00 R. Thomas Kline
00
4 12/03/2008
APOTHAKER & ASSOCIATES
Sworn and Subscibed to By:
before me this day
of A.D.
t :
Our File No.: 179650
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
Plaintiff,
VS.
THOMAS A PAULSON
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 08-6876
PRAECIPE TO DISMISS WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Kindly dismiss this action without prejudice.
APOTHAKER & ASSOCIATES, P.C.
Attorneys for ontq
A Law Firm Engaged ' eb Collectioi
By:
David J. Apothaker, Esquire
Dated: 3/24/2009