The URL can be used to link to this page

Home My WebLink About09-6815Our File No.: 222508 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. KIMBERLY KOSER 322 SANDBANK RD MOUNT HOLLY SPRINGS, PA 17065- 1131 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. ?Q IS of 0 iC Elpz? 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.: 222508 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. KIMBERLY KOSER 322 SANDBANK RD MOUNT HOLLY SPRINGS, PA 17065- 1131 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 KIMBERLY KOSER, an adult individual residing at 322 SANDBANK RD MOUNT HOLLY SPRINGS, PA 17065-1131. 3. At the special instance and request of Defendant, Plaintiff, DISCOVER BANK, issued to Defendant(s), Account #6011002440343051. 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 $7,212.92. 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 $7,212.92 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney for Plaintiff A Law Firm Engaged in Debt Collection BY: David J. A er, Esquire Dated: 10/8/2009 Our File No.: 222508 w 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. 4904 r 'ng to unworn falsification to authorities. David J. Apothaker, Esquire Attorney for Plaintiff DATE: 10/8/2009 DISCOVER CARD 18 SDSN8A01 0000396 KIMBERLY KOSER 322 SANDBANK RD MT HOLLY SPOS PA New Balance Minimum Payment Due $7,212.92 $684.00 Payment Due Deft Marsh 13, 2009 17065-1131 Account Number ending in 3051 Enter Amount Enclosed Below 1 Please make check payable to Discover Card. You areoverlimit. Pay the sum of the monthly minimum payment plus the overlimit amount of 5712.92. Will your payment got to us on time? Pay your bill online and your payment can be made to your account on the some day. Visit Discover.com/payments today. PO BOX 71084 CHARLOTTE HC 28272-1084 Address, e-mail ortelephone change? Print change inspace 1r,1u1n11rl1u11fill loll above, or go to Diseover.com. Print your e-mail address to receive important Account information and special offers. 00000198645856706658007212920000D000068400 Account number ending in Payment Due Date :Minimum Payment Due Credit Limit Credit Available :Cash Credit Limit `.Cash Credit Available page 1 of 1 3051 Previous Balance $6,955.57 March 15, 2009, Payments And Credits 0.00 $684.00 Purchases + 78.00 $6,500.00 Cash Advances + 0.00 $0.00 Balance Transfers + 0.00 $3,300.00 Finance Charges + 179.35 $0.00 New Balance = $7,212.92 You may be able to avoid Periodic Finance Charges, see the reverse side for details. :Cashback Bonuse Opening Cashback Bonus Balance $ 9.48 New Cashback Bonus Earned + 0.00 Redemptions This Period 9.48 !Gashback Bonus&Annlversa - - - - - -Cashback Bonus Balance... - - - - - - - - - - - $ ------ 0,00- - - -- - ry . 'Date: November 16 Available to Redeem $ 0.00 How Can We Help You? 1 • Visit Discover cam to pay your bill for no cost, view your latest Account information, corn and redeem rewards and more ;It's your choice - 3 ways to help 2. Call 1-800-DISCOVER (347-2683) for last, easy self-service options or to speak with a Customer Service Account Manager ;Please have Card available. your Discover 3. Write us at Discover Card, PO Box 30943, For TDD (assistance for hearing impaired) see reverse side Sail Lake City, UT 84130 Transactions $0 Fraud Liabirity Guarantee Use your Discover Card with confidence. Trans. Post Dab Date 0dw/Mle ellaneous Feb 16 Feb 16 OVERLiMIT FEE $ 39.00 Feb 16 Feb 16 LATE FEE 39.00 Information For You * *' ATTENTION Your account is seriou sly past due. Payment of the amount due and arrangements for future payments should be made immediately. 'Finance Charge Summary Nominal Transaction Average Daily ANNUAL ANNUAL Periodic Fee Daily Periodic PERCENTAGE PERCENTAGE FINANCE FINANCE Balances Rates RATES RATES CHARGES CHARGES !current billing period: 31 days ;Purchases $2276.22 0.08216% 29.99% F 29.99% $57.97 none Cash Advances $4765,76 0.08216% 29.99% F 29.99% $121.38 $0 ;Ths rates that apply to your Account are either fixed (F) or they may vary (V) as rated above. i Discover More Card Account Summary Closing Date: February 16, 2009 ? Q?l ALE CTARY Z 9 0 C T 13 PH 3: 24 476.ro,i??Cpl ?- a3r84g Sheriff s Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant ~~~ ~jt~• of ~anibrr~r ~ 7 ~,r~ c~ : .~~;F~ ,.~ , t' n ~~ ~..1 ,, ~ ,.~ .//., ~ ~ - ~.. ~--,~ Edward L Schorpp Solicitor Discover Bank Case Number vs. Kimberly S. Koser 2009-6815 SHERIFF'S RETURN OF SERVICE 10/19/2009 09:10 PM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on October 19, 2009 at 2110 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Kimberly S. Koser, by making known unto herself personally, at 322 Sand Bank Road Mount Holly Springs, Cumberland County, Pennsylvania 17065 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $34.30 SO ANSWERS, October 20, 2009 R THOMAS KLINE, SHERIFF ~'~~ ' ~~? Deputy riff A Our File No.: 222508 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. KIMBERLY KOSER Defendant. i ILED-OFFICE Or THE PROTHONOTARY 2012 JAN 13 AM i I : 31 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-6815 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER A Law Firm By: David J. A Dated: 12/29/2011 11111111111111111111 TES, P.C. Debt Collection , Esquire