The URL can be used to link to this page

Home My WebLink About09-7424Our File No.: 222659 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.438423 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. DARLENE R POINT 515 KEVIN CT CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: oq - 74a q y ivy l Iem 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.: 222659 APOTHAKER & ASSQCIATES, 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 ) COURT OF COMMON PLEAS c/o Apothaker & Associates, P.C. ) CUMBERLAND COUNTY 520 Fellowship Road C306 Mount Laurel, NJ 08054 ) NO.: D 9- '79;"1 Plaintiff, ) VS. ) DARLENE R POINT ) 515 KEVIN CT ) CAMP HILL, PA 17011 ) Defendant. ) 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 DARLENE R POINT, an adult individual residing at 515 KEVIN CT CAMP HILL, PA 17011. 3. At the special instance and request of Defendant, Plaintiff, DISCOVER BANK, issued to Defendant(s), Account #6011002794501296. 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 $6,882.69. 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 $6,882.69 and requests this Court award costs to the extent permitted by applicable law. f A71! TES, P.C. A Collecti BY: uire Dated: 10/21/2009 Our File No.: 222659 VERIFICATION David J. Apothaker. Esquire Esa. 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 relating to unsworn falsification to authorities. David Wr, Esquire Plaintiff DATE: 10/21/2009 New Balance Minimum Payment DISCOVER D e Account Number ending in 1296 $6,882.69 51,07aoo CARD Enter Amount Enclosed Below Payment Due Date N.vwl. ?t ?M7 $1 27 SDSN6A010003982 DARLENE POINT 515 KEVIN CT CAMP HILL PA 17011-1263 Address, e-mail or telephone changes! Print change in space above, or go to Discovw.com. Print your e-mail address to receive important Account information and special offers. PO 000001986458888024110068826900000060107400 ---------------------------------- --------- ------------ Discover Platinum Card Account Summary ------------------ Closing Date February 27, 2007 Account number ending in 1296 Previous Bolan e Payment Due Date March 26, 2007 Payments And redits Minimum Payment Due $1,074.00 purhhases Credit Limit $5,500.00 Cash Adva Credit Available $0.00 Balance Trans Cash Credit Limit $2,800.00 Finance Ch s Cash Credit Available $0.00 Now Ratner. You may be reverse side Mean make check payable to Discover Platinum Card. You are overlimit. P the sum of the month minimum payment plus the ovedimit ammof $1,381.69. Will your payment get to us on time8 Pay your bill online and your payment can be made to your account on the some day. Visit Discover.eom/payments today. ix 71084 IH??rILrr??lrll??rlr?rlll -OTTE NC 28272-1084 1111 1111111111 111111111111 1111h Rill page 1 of 1 $6,671.40 0.00 + 78.00 + 0.00 + 0.00 + 133.29 $6,882.4 le to avoid Periodic Finance Charges, see the details. Gashback Bonuto . Opening Ca k Bonus Balance $ 0.00 New Cashbac Bonus This Period + 0,00 Cashbock -Cashlsutk-8onus?Annivsrsary _ _ ... . us Balance $ 0.00 Date: May 27 How Can We Hel You? 1. Visit Disc P latest Ac .corn to pay yaw bA for no cost, view?your i f ti c Its your choice - 3 ways to help 2. Call 1-8 n orma on, *am and redeem r9wards and more SCOVER (347-2683) for fast, easy selFservice Please have your Discover Card available. options or speak with a Customer Service Account Manager 3" write at For TDD (assistance for hearing impaired) see reverse side Discover Card, PO Box 30943, Sant k Lake C t y, UT 84130 Transactions $0 Fraud Liability Guarantee Use your D over Card with confidence. Tra ns. P DDat Dab othw/Misaoilaneous Feb 27 Feb 27 OVERLIMIT FEE $ 39.00 Feb 27 Feb 27 LATE FEE 39.00 Information For You While we are permitted under the Cardmember Agreement to increase the was late we have chosen not to do s at thi ti W s on your Account because your payment , o s me. e have terminated, ho purchases and any special balance transfer rote, and applied the standard P - - - -- ever, any introductory or promotional note on R For purchases to your ou standing balance of - - purcFwses cnd bofcines transTers. Rowever, we rsseNe the right to increase i i a APita on your AccounfiFyou fail 1o pay FTie - _ _ _. _. m n mum payment due by the payment due date. See the Default Rate Plan a details. ction of the Cardmember Agreement for Finance Charge Summary Nominal Average Daily ANNUAL Daily Periodic PBICENTA Transaction ANNUAL Periodic F PERCB+ITAGE Balances Roles RATES 1tATES CHARGES CRAM current billing period: 31 days D-OFFICE OF THE FPo ,0N''OTARY 2099 OCT 28 PM 1 *- 0 3 OUN FY CUVI pp,4NSYLVk4A f'79. So PO ATr-y is (o t 78 ?[''? a 3a m'18 SHERIFF'S OFFICE OF CUMBE R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor of C11jnbrpf414 ¢FFIaE pF FME S-:RIFF 2009 NOV -4 AM H: : 04 Discover Bank vs. Darlene R. Point Case Number 2009-7424 SHERIFF'S RETURN OF SERVICE 11/02/2009 07:36 PM - Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on November 2, 2009 at 1936 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Darlene R. Point, by making known unto James Sneed, adult in charge at 515 Kevin Court Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $34.00 November 03, 2009 SO ANSWERS, 94? 40 e R THOMAS KLINE, SHERIFF By Deputy Sheriff (c) CountySuite Sheriff, i'eieoscft. Inc. Our File No.: 222659 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. DARLENE R POINT Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-7424 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys for P ntiff A Law Firm Engage ebt Collection By: David J. Ap&hak r, Esquire Dated: November 7, 2009 RLED-0. 'i"E F THE PIP ; -lnr IO ARY 2009 NOV 25 P 3: 53 JIM P7- -