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Home My WebLink About09-1090 V,'Ourlile No.: 103625 ` 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. LINDA D BILLER 2907 HARVARD AVENUE CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: O9 - 10q0 0iw T" 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 --Ourtile No.: 103625 "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. LINDA D BILLER 2907 HARVARD AVENUE CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 09- /090 cu"-?l -Ft-'t" 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 LINDA D BILLER, an adult individual residing at 2907 HARVARD AVENUE CAMP HILL, PA 17011. 3. At the special instance and request of Defendant, Plaintiff, DISCOVER BANK, issued to Defendant(s), Account #6011002350129763. 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 $7,101.65. 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 $7,101.65 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER SOCIATES, P.C. A Law Firm $hgaged in Dx6t Collection BY: David J. Apothaker, Esquire Dated: 2/11/2009 Our File No.: 103625 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 Ya.C.?.A. 4904 relating to unworn falsification to authorities. -id" Apothaker, Esquire Attorney for Plaintiff DATE: 2/11/2009 LINDA D BILLER 2907 HARVARD AVENUE CAMP HILL, PA 17011 STATEMENT OF ACCOUNT DISCOVER BANK Debtor's Name: LINDA D BILLER Account Number: 6011002350129763 Balance Due: $7,101.65 Our File No.: 103625 EXHIBIT "A" , 0o a - ?.r C SHERIFF'S RETURN - NOT FOUND CASE NO: 2009-01090 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DISCOVER BANK VS BILLER LINDA D R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT BILLER LINDA D but was unable to locate Her in his bailiwick. He therefore returns the (''()MDT.ATIKTT f. WVVPT( GV NOT FOUND , as to the within named DEFENDANT BILLER LINDA D 2907 HARVARD AVENUE CAMP HILL, PA 17011 PER CURRENT RESIDENT, DEFENDANT MOVED TO FLORIDA 3 YEARS AGO. NO INFORMATION AVAILABLE FROM POST OFFICE AFTER 3 YEARS. Sheriff's Costs: Docketing 18.00 Service 13.50 Postage .42 Surcharge 10.00 Not Found 5.00 46.92 _ r ??- So answer, R. Tho s Kline Sheriff of C mberland County APOTHAKER & ASSOCIATES 03/03/2009 Sworn and Subscribed to before me this day of A. D. CL LLJ cL U - 0 cm 0 C%4 Our File No.: 103625 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. LINDA D BILLER Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-1090 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & Attorneys A Law Firm EngaQ By: TES, P.C. in Debt Collection David J. Apothaker, Esquire Dated: 3/17/2009 '".' t ? ? ? ? ?" :? ? o .' _ T %' 7 f_"` ?+-. .- ? _ . '?? ? .: -. - t-r"i ?i ;??