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Home My WebLink About09-5937 Our File No.: 222290 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. MATTHEW W PRICE 108 GILBERT RD SHIPPENSBURG, PA 17257-9409 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Oq - n3'1 0,1vit-Tem 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.: 222290 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. MATTHEW W PRICE 108 GILBERT RD SHIPPENSBURG, PA 17257-9409 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 MATTHEW W PRICE, an adult individual residing at 108 GILBERT RD SHIPPENSBURG, PA 17257-9409. 3. At the special instance and request of Defendant, Plaintiff, DISCOVER BANK, issued to Defendant(s), Account #6011298686883681. 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 $8,793.19. 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. WJIEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $8,793.19 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & AS Attorney f r A Law Firm Enaa ed , MATES, P.C. Debt Collection BY: David J. *po` Baker, Esquire Dated: 8/26/2009 Our File No.: 222290 VERIFICATION David J Apothaker Esquire Esg 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. 444 relating to unworn falsification to authorities. David J. A?othaker, Esquire Attorney for Plaintiff DATE: 8/26/2009 DISCOVER BANK MATTHEW W PRICE 108 GILBERT RD SHIPPENSBURG, PA 17257-9409 STATEMENT OF ACCOUNT Debtor's Name: MATTHEW W PRICE Account Number: 6011298686883681 Balance Due: $8,793.19 Our File No.: 222290 EXHIBIT "A" Q OF THE 2M AUG 31 It'? 1, i2: 02 'UNTY fytiA ?v $ ?8.5o pb AITY CI?,* ttf8'7'13 QTV aag98l Sheriff s Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor ~4~~~t~ of ~iuub~~f_r~~ y ;. ,. S2f ctCF, .:c- T~-E ~ ~FRIFI~ ~~ ~jL~i~ ~~ i l~~ TNT ~ ~~ ~-ri.;~f~r~?'~'~3Y 20Q9 SEP ! 0 Pi's 3~ 3 ~ Discover Bank vs. Matthew W. Price Case Number 2009-5937 SHERIFF'S RETURN OF SERVICE 09/04/2009 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: Matthew W. Price, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Matthew W. Price. The Landlord of 108 Gilbert Road Shippensburg, PA 17257 stated Matthew W. Price moved to New Hampshire a month ago. The Shippensburg Postmaster has advised the defendant's mail is delivered to address given. An exact address is not available. SHERIFF COST: $51.00 SO ANSWERS, September 04, 2009 R THOMAS KLINE, SHERIFF ' Our File No.: 222290 APOTHAKER & ASSOCIATES P.C , , . BY: David J. A othaker Esquire T -7) ' Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff v DISCOVER BANK Plaintiff, vs. MATTHEW W PRICE Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-5937 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & A Law Firm By: David J TES, P.C. in Debt Collection , Esquire Dated: 4/9/2012