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Home My WebLink About09-2480 Our File No.: 204170 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. NORMA MARTELL A/K/A NORMA PUCCINA 620 BRENTON ST SHIPPENSBURG, PA 17257 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: CR - 01gS0 (" ivtil terk 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.: 204170 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. NORMA MARTELL A/K/A NORMA PUCCINA 620 BRENTON ST SHIPPENSBURG, PA 17257 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT I. Plaintiff is DISCOVER BANK c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are NORMA MARTELL A/K/A NORMA PUCCINA, an adult individual residing at 620 BRENTON ST SHIPPENSBURG, PA 17257. 3. At the special instance and request of Defendant, Plaintiff, DISCOVER BANK, issued to Defendant(s), Account #6011002090654013. 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 $7,737.68. 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 $7,737.68 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATE-S, P.C. Attorney for Pl 'tiff / A Law Firm Engaged i ebt Collection BY: David J. Dated: 4/10/2009 Our File No.: 204170 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.S.A/490?relating to unworn falsification to authorities. David J?pothaker, Esquire Attorn v for Plaintiff DATE: 4/10/2009 DISCOVER BANK NORMA MARTELL A/K/A NORMA PUCCINA 620 BRENTON ST SHIPPENSBURG, PA 17257 STATEMENT OF ACCOUNT Debtor's Name: NORMA MARTELL'A/K/A NORMA PUCCINA Account Number: 6011002090654013, Balance Due: $7,737.68 Our File No.: 204170 EXHIBIT "A" O inTADV 2D09 APR 20 PH 1: 49 { _ \ S tt 1.. rti 419.50 PD ATty '?* 1186 ?' ? 398v1 Sheriffs Office of Cumberland County R Thomas Kline ?0?ti1tr of irsmbr. Edward L Schorpp Sheriff Solicitor Ronny R Anderson Jody S Smith Chief Deputy oFV CE ` THE s"ERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/24/2009 04:00 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on April 24, 2009 at 1600 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Norma Martell, by making known unto Albert Penchi, husband of defendant, at 620 Brenton Street, Shippensburg, Cumberland County, Pennsylvania, 17257, its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $46.00 April 27, 2009 SO ANSWERS, ?? 0 I R THOMAS KLINE, SHER FF 7?• 7? De t eri Docket No. 2009-2480 Discover Fzank v Normal Martell n "Z3 _It C= N) 7! ?•?•y L i „ qJ 1 ,? r Q .'? , c=) M ? 1 Our File No.: 204170 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. NORMA MARTELL A/K/A NORMA PUCCINA Defendant. NO. 09-2480 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys f laintiff A Law Firm Eng ed ' Debt Collectior By: David J. Apothaker, Esquire Dated: 5/15/2009 !tr- t ;' _ , 1 ray 2 0 0 9 K:AY w2 P z 2: {7 CU% i oy t log