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Our File No.: 234347
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.
KENNETH W APGAR
114 N 21ST ST
CAMP HILL, PA 17011-3808
Defendant.
1Ji TY- 1"czi0 ,N0TARY
2010 JAN 12 AM 9: 38
- DUN
PE `vt,'SYLVAA
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: !O - 315
Oivil-hm
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
4q01. 00 PD, A" Y
L'e I104100q
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Our File No.: 234347
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 ) COURT OF COMMON PLEAS
c/o Apothaker & Associates, P.C. ) CUMBERLAND COUNTY
520 Fellowship Road C306 )
Mount Laurel, NJ 08054 ) NO.:
Plaintiff, ) / 0 - 3 3 C N`
vs. )
KENNETH W APGAR )
114N21STST )
CAMP HILL, PA 17011-3808 )
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 KENNETH W APGAR, an adult individual residing at 114 N 21ST ST
CAMP HILL, PA 17011-3808.
3. At the special instance and request of Defendant, Plaintiff, DISCOVER BANK, issued to
Defendant(s), Account #6011002530615970.
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 $7,425.88. 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
$7,425.88 and requests this Court award costs to the extent permitted by applicable law.
APOTHAKER &
Attorney
A Law Firm Eng
BY:
David J. n
kTES, P.C.
Debt Collection
Dated: 12/31/2009
Our File No.: 234347
VERIFICATION
David J. Apothaker Esquire Esy 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. 04 r lating to unsworn falsification to authorities.
David J. A othaker, Esquire
Attorne or Plaintiff
DATE: 12/31/2009
4L
DISCOVER BANK
KENNETH W APGAR
114 N 21 ST ST
CAMP HILL, PA 17011-3808
STATEMENT OF ACCOUNT
Debtor's Name: KENNETH W APGAR
Account Number: 6011002530615970
Balance Due: $7,425.88
Our File No.: 234347
EXHIBIT "A"
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronny R Anderson
Sheriff
Jody S Smith
Chief Deputy
Edward L Schorpp
Solicitor
1r T4
E
2010 &H 21 A'I 9: 4-?
Discover Bank
vs.
Kenneth W. Apgar
Case Number
2010-313
SHERIFF'S RETURN OF SERVICE
01/19/2010 08:24 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on
January 19, 2010 at 2024 hours, she served a true copy of the within Complaint and Notice, upon the
within named defendant, to wit: Kenneth W. Apgar, by making known unto himself personally, at 114 N.
21st Street, 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: $41.50
January 20, 2010
SO ANSWERS,
Y R ANDERSON, SHERIFF
By ? C&Lj
Deputy Sheriff
Ar
Our File No.: 234347
APOTHAKER & ASSOCIATES, P.C.
BY: David J. Apothaker, Esquire
Attorney I.D.# 55140
520 Fellowship Road C306
Mount Laurel, NJ 08054
(800) 672-0215
Attorney for Plaintiff
DISCOVER BANK
Plaintiff,
vs.
KENNETH W APGAR
Defendant.
2010 FEB 22 Ph i2* 5 7
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
)
NO. 10-313
PRAECIPE TO DISMISS WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Kindly dismiss this action without prejudice.
APOTHAKER & ASSOCIATES, P.C.
Attorneys for PI ' ff
A Law Firm Engaged i94 Collection
By:
David J. Apotha er, Esquire
Dated: 2/15/2010