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Home My WebLink About09-2223,.Our We'No.: 204155 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. JUNE C JURICK 5 DEWALT DR MECHANICSBURG, PA 17050-1724 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CR - =5 alvit lerok 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.: 204155 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. JUNE C JURICK 5 DEWALT DR MECHANICSBURG, PA 17050-1724 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 q - ,2 -)- --2 3 Cwil -a.- 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 JUNE C JURICK, an adult individual residing at 5 DEWALT DR MECHANICSBURG, PA 17050-1724. 3. At the special instance and request of Defendant, Plaintiff, DISCOVER BANK, issued to Defendant(s), Account #6011005069002031. 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 $2,322.46. 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 $2,322.46 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASS TES, P.C. Attorney for tiff A Law Firm Engage in bt Collection BY: David J. AliothaRK, Esquire Dated: 4/3/2009 Our File No.: 204155 VERIFICATION David I Apothaker Esquire. Esa 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.S.A. 4.9?4 relating to unworn falsification to authorities. David I othaker, Esquire Attorne for Plaintiff DATE: 4/3/2009 DISCOVER BANK JUNE C JURICK 5 DEWALT DR MECHANICSBURG, PA 17050-1724 STATEMENT OF ACCOUNT Debtor's Name: Account Number: Balance Due: Our File No.: 204155 JUNE C JURICK 6011005069002031 $2,322.46 EXHIBIT "A" G) l FILED-OF IQt OF TFfE P 3THONOTARY 2009 APR -9 AM 11: 20 t ,-;U1ai f PD,IN S Y W:N, +18. so po ATN ao ta9130 ?,,U3SDQ Sheriffs Office of Cumberland County R Thomas Kline $tti?,tr et a+?Lrr/;Edward L Schorpp Sheri Solicitor > - : Y Ronny R Anderson Jody S Smith Chief Deputy oF? cE r '',s ss?rr Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/13/2009 08:30 PM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: June C. Jurick, but was unable to locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant June C. Jurick. MichelkJurick, resident at 5 Dewalt Driv%Mechanicsburg, Silver Spring Township, Cumberland County 17050 and daughter in law of defendant states that June C. Jurick is living in a nursing home in Ohio. The exact address is not available. SHERIFF COST: $43.80 April 14, 2009 2009-2223 Discover Bank VS. June C. Jurick SO ANSWERS, R THOMAS KLINE, SHERIFF FILED -.,,-,e- OF THE Mlf-! ;?,,, , 2009 APP 20 AM 8= 4 7 r Our File No.: 204155 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. JUNE C JURICK Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-2223 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plaintiff A Law Firm Engaged iylb5 bt Collection By: David J. Apothaker, Esquire Dated: June 23, 2009 FUD-OFFICE OF THE PPOTHONOT,ARY 2N9 JUN 29 PM 3: 31 CUMBE' k,,,x•40 (WNTY PENNSYLVANIA,