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Our File No.. 204173
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.
KATHLEEN A CYR
51 DEADEND IN
SHIPPENSBURG, PA 17257-8619
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: oq _ j3 s - l 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
Our F41e No;: 204173
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 ) COURT OF COMMON PLEAS
c/o Apothaker & Associates, P.C. ) CUMBERLAND COUNTY
520 Fellowship Road C306 )
Mount Laurel, NJ 08054 ) NO.:
Plaintiff, )
VS. )
KATHLEEN A CYR )
51 DEADEND LN )
SHIPPENSBURG, PA 17257-8619 )
Defendant. )
CIVIL ACTION COMPLAINT
FIRST COUNT
Plaintiff is DISCOVER BANK c/o Apothaker & Associates, P.C., 520 Fellowship Road C306,
Mount Laurel, NJ 08054.
2. Defendant(s) is/are KATHLEEN A CYR, an adult individual residing at 51 DEADEND LN
SHIPPENSBURG, PA 17257-8619.
3. At the special instance and request of Defendant, Plaintiff, DISCOVER BANK, issued to
Defendant(s), Account #6011003477457053.
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 $10,880.05. 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
$10,880.05 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable
law.
APOTHAKER &
Attorney
A Law Firm Enzaf
BY:
David J.
Dated: 4/8/2009
kTES, P.C.
Debt Collection
Our File No.: 204173
VERIFICATION
David J. Apothaker Esquire Esc,. 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. 490 ela g to unworn falsification to authorities.
David J. A thaker, Esquire
Attorney r Plaintiff
DATE: 4/8/2009
DISCOVER BANK
KATHLEEN A CYR
51 DEADEND LN
SHIPPENSBURG, PA 17257-8619
STATEMENT OF ACCOUNT
Debtor's Name: KATHLEEN A CYR-
Account Number: 6011003477457053
Balance Due: $10,880.05
Our File No.: 204173
EXHIBIT "A"
CF Tj-'i LE
Y
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Sheriffs Office of Cumberland County
R Thomas Kline u?,tir u, LSolicitor
Sheriff
Ronny R Anderson Jody S Smith
Chief Deputy OFFICE of THE SHERIFF Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
04/17/2009 09:27 AM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on April
17, 2009 at 0927 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Kathleen A. Cyr, by making known unto Kathleen A. Cyr personally, at 51 Deadend
Lane, Shippensburg, Cumberland County, Pennsylvania, 17257 its contents and at the same time handing
to her personally the said true and correct copy of the same.
SHERIFF COST: $46.00 SO ANSWERS,
April 21, 2009 ------R THOMAS KLNE, SHERIFF
f
Docket NO. 2009-2368
Discover Bank v Kathleen Cyr
OF THE PKI'210NOTARY
2009 APR 24 P 3: 04
_ : ?
CUM,
4.
Our File No.: 204173
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.
KATHLEEN A CYR
NO. 09-2368
Defendant.
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 in Debt Collection
By:
Da
Dated: May 22, 2009
1 0-.
OF THE FF." f ,INTARY
2009 JUN -2 All i 1