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Home My WebLink About09-7113Ourl'ile No.: 226798 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#3$423 520 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. SCOTT ALLEN KUNTZELMAN 125 ALTOONA. AVE ENOLA, PA 17025-2503 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Oq- 1/13 a-tvit-wr% 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.: 226798 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. SCOTT ALLEN KUNTZELMAN 125 ALTOONA AVE ENOLA, PA 17025-2503 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 01?- Vl3 et' tqj 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 SCOTT ALLEN KUNTZELMAN, an adult individual residing at 125 ALTOONA AVE ENOLA, PA 17025-2503. 3. At the special instance and request of Defendant, Plaintiff, DISCOVER BANK, issued to Defendant(s), Account #6011002980179469. 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 $10,584.77. 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 $10,584.77 and requests-this Court award costs to the extent permitted by applicable law. APOTHAKER & Attorney or TlaCinItAiffTES'P-C- A Law Firm Eng ed Debt Collection BY: David J. Dated: 10/9/2009 Our File No.: 226798 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, therein are made subject to the penalties of 18 Pa.C.S The undersigned understands that the statements relating to unsworn falsification to authorities. David J. Apethaker, Esquire Attorney for Plaintiff DATE: 10/9/2009 DISCOVER BANK SCOTT ALLEN KUNTZELMAN 125 ALTOONA AVE ENOLA, PA 17025-2503 STATEMENT OF ACCOUNT Debtor's Name: SCOTT.ALLEN KUNTZELMAN Account Number: 6011002980179469 Balance Due: $10,584.77 Our File No.: 226798 EXHIBIT "A" Q FILE' THE P ,wG0?ARY 2009 OCT 16 PH 2: 1 *1 i"C, .iy',, i L.,VO. i!,A !f?8.50 PA A`n`f (+x,? CSHS+ES Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor FILED-awiCE OF THE F90TP,()-%fOTARY Discover Bank vs. Scott Allen Kuntzelman 1009 OCT 28 AM 9: 42 f FIN1VSYLVA'NA Case Number 2009-7113 SHERIFF'S RETURN OF SERVICE 10/26/2009 07:50 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on October 26, 2009 at 1950 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Scott Allen Kuntzelman, by making known unto himself personally, at 125 Altoona Avenue Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to hirr personally the said true and correct copy of the same. SHERIFF COST: $55.00 SO ANSWERS, October 27, 2009 R THOMAS KLINE, SHERIFF BY ?? puty Sheriff 4 Our file No.: 226798 -?j APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff Attorney ID# 55140 ?j r! 0 V DISCOVER BANK Plaintiff, VS. SCOTT ALLEN KUNTZELMAN Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 09-7113-CIVIL TERM Civil Action STIPULATION IN LIEU OF JUDGMENT The matters and things in controversy having been discussed by and between the parties, and a settlement having been agreed upon: It is on October 29, 2009, STIPULATED by and between Plaintiff, DISCOVER BANK, and Defendant, SCOTT ALLEN KUNTZELMAN parties as follows: 1. Defendant agrees to pay the sum of $10,763.27, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. As of this date, payments totaling $299.00 have been applied to the amount of $10,763.27, and the amount due and owing as of October 29, 2009 is $10,464.27. 3. The sum aforesaid of $10,464.27 shall be paid by the by Defendant, SCOTT ALLEN KUNTZELMAN, to the attorneys for Plaintiff in the following manner: a. $299.00 to be paid on or before the 22nd of each month, beginning November 22, 2009 until paid in full. All checks are to made payable to DISCOVER BANK, and sent to: Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Our file No.: 226798 4. In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation, then, and in that event, Plaintiff shall be entitled to obtain the entry of Judgment against Defendant ex parte, in the sum of $10,763.27, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. 5. In the event of default as aforesaid, Plaintiff shall be entitled to obtain the entry of Judgment upon ex parte application, with supporting certification, and with notice to Defendant only in the form of a copy of the application addressed to SCOTT ALLEN KUNTZELMAN by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plaintiff A Law Firm Engaged fi>bebt Collectioi By: F. Scian, Esquire SCOTT LE KUNTZELMAN Our File No.: 226798 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. SCOTT ALLEN KUNTZELMAN S? E GI 2012 HAR 19 PH 1: 22 "UPENSYLVANIUNrY A COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-7113-CIVIL TERM Defendant PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & AS-50CIATES, P.C. A Law Firm Eng4ed W Debt Collection By: David J. Apo {er, Esquire Dated: 3/13/2012 1