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Home My WebLink About09-5624Our File No.: 216383 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. DONNA L HAGARMAN 48 RIDGEWAY DR MECHANICSBURG, PA 17050-7974 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Dq _ 5(oaq aivt l (?rrn 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.: 216383 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. DONNA L HAGARMAN 48 RIDGEWAY DR MECHANICSBURG, PA 17050-7974 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 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 DONNA L HAGARMAN, an adult individual residing at 48 RIDGEWAY DR MECHANICSBURG, PA 17050-7974. 3. At the special instance and request of Defendant, Plaintiff, DISCOVER BANK, issued to Defendant(s), Account #6011002750312738. 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 $14,437.09. 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 $14,437.09 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSO ES, P.C. Attorney for P t A Law Firm Engaged t Collection BY: Dated: 8/6/2009 David J. AnotlUer.-U uire Our File No.: 216383 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. 4004 #elating to unsworn falsification to authorities. David J. Apo??Esqui Attorney for Plaintiff DATE: 8/6/2009 DISCOVER BANK DONNA L HAGARMAN 48 RIDGEWAY DR MECHANICSBURG, PA 17050-7974 STATEMENT OF ACCOUNT Debtor's Name: DONNA L HAGARMAN Account Number: 6011002750312738 Balance Due: $14,437.09 Our File No.: 216383 EXHIBIT "A" Q F;LI: n . r' 1 4'78.50 PQ AT N I qb 17 70 aagiy3 Sheriffs Office of Cumberland County R Thomas Kline Sheri ?4t3r?tu nt ?ir?i?brry??? OFF iCrE OFTkE sHERirF FLED-.,-,f- `''CE OF THE F -r- - Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor ZrM AUG- 28 P1112:572 t'"Y Discover Bank vs. Donna L. Hagarman Case Number 2009-5624 SHERIFF'S RETURN OF SERVICE 08/21/2009 03:37 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on August 21, 2009 at 1537 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Donna L. Hagarman, by making known unto herself personally, at 48 Ridgeway Drive Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 August 24, 2009 SO ANSWERS, ?wmaaw R THOMAS KLINE, SHERIFF By Deputy Sheriff IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION AT LAW DISCOVERY BANK, Plaintiff VS. DONNA L. HAGARMAN, Defendant No. 09-5624 Civil Term ANSWER AND NOW, comes the Defendant, Donna L. Hagarman, through her attorney, Steven M. Carr, Esq., of the firm of Ream, Carr, Markey & Woloshin, LLP, and files this Answer to Plaintiff's Complaint as follows: 1. Admitted. 2. Admitted. 3. Admitted. 4. Admitted. 5. Denied. It is denied that the amount due and owing is listed in Exhibit A. 6. Admitted. 7. Denied that $14,437.09 is due. WHEREFORE, Defendant prays that this Honorable Court enter judgment in her favor and against Plaintiff dismissing Plaintiff's complaint. Respectfully submitted, REAM, CARR, MARKEY & WOLOSHIN, LLP k V? By: zr'? ? C-? Stev .,Carr, Esq. 119 E. Market Street York, PA 17401 Phone: 717-843-8968 Fax: 717-846-4999 Email: carr20kaol.com PA 34336 t- ' VERIFICATION I verify that the statements made in the foregoing document are true and correct to the best of my knowledge. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S. Sec. 4904 relating to unsworn falsification to authorities. Steve . Carr, Esq. Attor , tiey Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION AT LAW DISCOVERY BANK, No. 09-5624 Civil Term Plaintiff VS. DONNA L. HAGARMAN, Defendant CERTIFICATE OF SERVICE I, Steven M. Carr, Esquire, attorney for Plaintiff, hereby certify that on this day I served a true and correct copy of the attached document upon the following person by depositing same in the U.S. Mail, first class postage prepaid, addressed as follows: David J. Apothaker, Esq. Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 9 _Lf-.a9 Date: REAM, CARR, MARKEY & WOL IN, By: M. Carr, Esquire S4 v 119 East Market Street York, PA 17401 Phone: (717) 843-8968 Fax: (717) 846-4999 Email: carr2Okaol.com PA 34336 RLED-0, "'CE OF TH_Ft"?T5't?T,ARY 2009 SEP -9 PM 12. 3G CUr !iv tY