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HomeMy WebLinkAbout04-2574 Our File No. 185303 ATTORNEYS FOR PLAINTIFF ERIC M. BERMAN, P.C. BY: Eric M. Berman, Esquire, I.D. 83698 BY: Robert M. Kline, Esquire,I.D. 56479 198 Allendale Road, Suite 306 King of Prussia, PA 19406 (610) 265-7720 -----------------------------------------X ~ COURT OF COMMON PLEAS COUNTY OF CUMBERLAND : DISCOVER BANK c/o ERIC M. BERMAN, P.C. 198 Allendale Road, Suite 306 King of Prussia, PA 19406 : TRIAL DIVISION CIVIL ACTION vs. Term : TRACEY E GLESSNER 14 S BROAD ST # 14B MECHANI CSBURG, PA 17055 3705 -----------------------------------------x No. 01./ - ;2S/'t'f 11. ~ "'" Crull LEJ_ J NOTICE TO DEFEND 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 this complaint or for any other claim or relief required 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 00 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. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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. LAWYER REFERENCE SERVICE COUWfY OF CUMBERLAND BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PA 17013 800-990-9108 Our File No. 185303 ATTORNEYS FOR PLAINTIFF ERIC M. BERMAN, P.C. BY: Eric M. Berman, Esquire, I.D. 83698 BY: Robert M. Kline, Esquire,I.D. 56479 198 Allendale Road, Suite 306 King of Prussia, PA 19406 (610) 265-7720 -----------------------------------------X DISCOVER BANK c/o ERIC M. BERMAN, P.C. 198 Allendale Road, Suite 306 King of Prussia, PA 19406 COURT OF COMMON PLEAS COUNTY OF CUMBERLAND CIVIL ACTION Term No. vs. TRACEY E GLESSNER 14 S BROAD ST # 148 MECHANICSBURG, PA 17055 3705 -----------------------------------------x COMPLAINT 1. Plaintiff, DISCOVER BANK , is a DELAWARE STATE BANK authorized to do business in the Commonwealth of Pennsylvania with its place of business at 3311 MILL MEADOW DRIVE, HILLIARD, OH 43026. 2. The Defendant(s), TRACEY E GLESSNER , resides at 14 S BROAD ST # 14B , MECHANICSBURG, PA 17055-3705. 3. There is due from the Defendant(s) the sum of $13,612.91 for credit extended by Plaintiff to Defendant(s), acct. no. 6011002500003603, and which such credit was drawn and used by the Defendant(s). Defendant(s) is in default for failure to make payments for such use. 4. The Plaintiff has made demand upon the Defendant(s) for payment of monies in the sum of $13,612.91 advanced to Defendant(s) through Defendant(s) use of the above-referenced credit account, but Defendant(s) has failed and refused to pay the said sum or any part thereof. 5. All applicable credits, if any, have been duly applied to Defendant(s) credit account. WHEREFORE, Plaintiff claims of the Defendant(s) the sum of $13,612.91 plus interest, attorneys fees and costs which are justly due and owing from the Defendant(s) to the Plaintiff. Dated: MARCH 01, 2004 ERIC M~N, P.C. BY: Lvt~ ERIC M. BE~,-ESQUIRE BY: ...- '------ ROBERT M. KLINE ESQUIRE SPACEBNW-ZN Attorneys for Plaintiff VERIFICATION Eric M. Berman, Esquire, being duly sworn according to law, deposes and says that he is the Principal attorney of Eric M. Berman, P.C., attorneys for the Plaintiff, and/or Robert M. Kline, Esquire, being duly sworn according to law, deposes and says that he is an associate attorney with said firm, and as said attorney, is authorized to take this verification on its behalf, and that the facts in the Complaint as set forth therein are true and correct to the best of his knowledge, information and belief. I verify that the statements made in the within instrument are true and correct. I understand that false statements are subject to the penalties of 18 Pa C.S.A. Section 4904 relating to unsworn falsifications to authorities. c~ ERIC M. BE~N, ESQUIRE L--- ROBERT M. KLINE, ESQUIRE Dated: MARCH 01, 2004 SPACEBNW-ZN 10 P .tQ. ~ 'l 111 (J') "'- "'- Ul .so ci1 C> :a 0 -u -c) P- 1- (-" ,.....~'l C:J 0 {....:- -,-) c_ --I -r h::",:!J rT' ,', ~ 1 __1 , - ~~'~'), (,,':' en ...- SHERIFF'S RETURN - NOT FOUND CASE NO: 2004-02574 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND DISCOVER BANK VS GLESSNER TRACEY E R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT GLESSNER TRACEY E but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE NOT FOUND , as to the within named DEFENDANT , GLESSNER TRACEY E 14 S BROAD ST #14B MECHANICSBURG, PA 17055 UNABLE TO SERVE PRIOR TO EXPIRATION. DEPUTIES INDICATED THAT THERE WAS OBVIOUSLY SOMEONE HOME, BUT NO ONE WOULD ANSWER THE DOOR. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 29.60 5.00 10.00 .00 62.60 so~ ..-----:;;' R. Thomas Kline Sheriff of Cumberland County ERIC BERMAN 07/08/2004 Sworn and subscribed to before me this I.JI{:. day of ~ 2<ro'( A.D. U. , Q. IrWP,^, Y1~J ~notary J ._," ERIC M. BERMAN, P.C. BY: Robert M. Kline Esq. Attorney for Plaintiff Attorney # 56479 198 Allendale Road, Suite 306 King of Prussia, PA 19406 (610) 265-7720 DISCOVER BANK clo Eric M. Berman, P.C. 198 Allendale Road, Suite 306 King of Prussia, P A 19406 COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION LAW Plaintiff v. CASE NO.: 04-a574 TRACEY E. GLESSNER PLAINTIFF'S MOTION FOR AL TERNA llIVE SERVICE I. Plaintiff, by and through its undersigned coullsel, filed its Complaint against Defendant on or about June 17,2004. 2. Plaintiff sought service of said Complaint upon Defendant on or about July 8, 2004. Service of Process by the Sheriff was not obtaiined. A true and correct copy of Sheriff's Order For Service is attached hereto and marked Exhibit "A." 3. Plaintiff inquired of the postal authorities pmsuant to the Freedom Information Act, 39 C.F.R. Part 265, to learn that the address of the Defendant whereupon the Sheriff sought to serve the complaint is the Defendant's correct address. A true and correct copy of the Freedom of Information nequest is attached hereto and marked Exhibit "B." avail. 4. Plaintiff consulted various on-line address and telephone directories, to no 5. Plaintiff requests that the Court allow Alternative Service by ordinary and certified mail, return receipt requested: to wit, Pa.R.Civ.P. 430 provided that the Plaintiff may move the Court for a special order directing the method of service if service cannot be made and a good faith effort to serve the complaint by regular service has been made. WHEREFORE, Plaintiff respectfully requests that this Honorable Court grant its Motion for Alternative Service of the Complaint by ordinary and certified mail, return receipt requested, upon Defendant. The Complaint shall be deemed as served if the requirements ofPa.R.Civ.P. 403 relating to se ice by mail are met. BY: Robert M. Kline, Esquire Attorney for Plaintiff DATED: August 2, 2004 DISCOVER BANK c/o ERIC M. BERMAN, P.C. 198 Allendale Road, Suite 306 King of Prussia, PA 19406 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff V. CIVIL ACTION-LAW CASE NO. TRACEY E. GLESSNER PROOF OF ATTEMPTS TO SERVE DEFENDANT IIJY REGULAR SERVICE I. I, Robert M. Kline, Esquire certify that on June 17, 2004, I filed a Civil Complaint against the Defendant TRACEY E. GLESSNER. I sent a copy ofthe Complaint to the Sheriff to make service of Process at 14 S. Broad Street Fl. 2 Mechanicsburg, PA 17055. The Sheriff was unable to make service upon Defendant. A true and correct copy of Sheriffs Order For Service is attached hereto and marked Exhibit "A." 2. I then sent a request to the postal authorities in Mechanicsburg, P A 17055, to verify that the Defendant's address was correct. The Postmaster verified that Defendant continues to reside/receive mail at 14 S. Broad Street Fl. 2. A copy of the Postmaster's response is attached. 3. I consulted various on-line address and telephone directories to verify Defendant's address, to no avail. AFFIDAVIT COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND I, Robert M. Kline, Esquire herby certify that the statements made in the foregoing Proof of Attempts to serve Defendant by Regular Service are true and correct to the best of my knowledge, information and belief and that said statements are made subject to the penalties of 18 Pa. C.S.A./4904 relating to unsworn falsification to ~oritie~ DATED: August 2, 2004 Robert M. Kline, Esquire Attorney for Plaintiff-Movant Postmaster: ~'4 /70.5S Date: REQUEST FOR CHANGE OF ADDRESS OR BOXHOLDER INFORMATION NEEDED FOR SERVICE OF LEGAL PROCESS 7- /~-o<l NOTE: The name and last known address are required for change of address infimnation. The name, if known and post office box address are required for boxhoJder infonnation. The fOllowing infonnation is provided in accordance with 39 CFR 265.6(d) (4) (ii). There is no fee for providing boxholder infonnation. The fee for providing change of address infonnation is waiv,ld in accordance with 39 CFR 265.6(d) (I) and correspondence Administrative Support Manual 352.44a. 1. Capacity of requester (e.g., process served, attorney, party representing selO: Attorney 2. Statute or regulation that empowers me to serve process (not required whe<< requester is an attorney or a party acting pro se except a corporation acting pro se mUst cit statu~: 3. The names of all known parties to the litigation: c.&v-(/) ,A ~ . 4. The Court in which the case has been or will be heard: "--' H~ 5. The dOCket or other identilYing number if one has been issued: Olf _ a 574 6. n.__.... .,...,..... ,..~-(~.-...,._). dg'< , ,tl;' d W ARNlNG THE SUBMISSION OF FALSE INFORMATION EITHER (/) TO OBTAIN AND USE CHANGE OF ADDRESS INFORMATION OR BOXHOLDER INFORMATION FOR ANY PURPOSE OTHER THAN THE SERYIC:E OF LEGAL PROCESS IN CONNECT/ON WITH ACTUAL OR PROSEPECT/VE LITIGATION OR (2) TO A VOID PAYMENT OF THE FEE FOR CHANGE OF ADDRESS INFORMATION COULD RESULT IN CRIMINAL PENALTIES INCLUDING A FINE OF UP TO $10,000 OR IMPRlSIONMEm OF NOT MORE THAN 5 YEARS, OR BOTH (TITLE 18 U.S.C. SECTION 1001) I certify that the above infonnation is true and that the address infonnation is needed and will be used solely for services oftegal process in ~rospective litigation. Signature: Printed Name: &kxrt {'(j. t:...J j ()~ _ Address: Robert M. Kline, Esquire Eric M Bennan, P.C. 198 Alle"dale Road, Suite 306 King of Prussia, PA 19406 / Good as addressed. City, State, Zip FOR POST OFFICE USE ONLY - No change of address order on tile. NEW ADDRESS OR BOXHOLDER'S NAME AND STREET ADDRESS - Not know at address given. - Moved, left no fonvarding address. No such address. -~----------------_._~ SHERIFF'S RETURN - NOT FOUND CASE NO: 2004-02574 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND J 3:;305 DISCOVER BANK VS GLESSNER TRACEY E R. Thomas Kline ,Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT GLESSNER TRACEY E but was COMPLAINT & NOTICE unable to locate ~ in his bailiwick. He therefore returns the the within named DEFENDANT , NOT FOUND , as to , GLESSNER TRACEY E MECHANICSBURG, PA 17055 14 S BROAD ST #14B UNABLE TO SERVE PRIOR TO EXPIRATION. DEPUTIES INDICATED THAT THERE WAS OBVIOUSLY SOMEONE HOME, BUT NO ONE WOULD ~~SWER THE DOOR. Sheriff's Costs: Docketing Service Not Found Surcharge 18.00 29.60 5.00 10.00 ..00 62.60 SO~~ R. Thomas Kline Sheriff of Cumberland County ERIC BERMAN 07/08/2004 Sworn and subscribed to before me this dcty of A.D. Prothonotary DISCOVER BANK c/o ERIC M. BERMAN, P.C. 198 Allendale Road, Suite 306 King of Prussia, P A 19406 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff CIVIL ACTION-LAW CASE NO. 04-2574 V. TRACEY E. GLESSNER CERTIFICATION OF MAILING COMMONWEALTH OF PENNSYLVANIA SS COUNTY OF CUMBERLAND I, Robert M. Kline, Esquire, being duly sworn according to law, herby certified that on ,20_, a true and correct copy of Plaintiff's Motion for Alternative Service was served by mailing same by United States first-class mail, postage prepaid, to Defendant at 14 S. Broad Street FI. 2 M(:chanics~ DATED: August 2, 2004 BY: Robert M. Kline, Esquire -"1 ,..,'--, i~ '" CO> C~~ ..r- ",. C"" C::-j I L() :t-"" :.1:: \9 !'-, (,.i"j o " ~ rei, f"R -Q;'Tl ::.)C7 ()..L ::i:! ~-/ ':::,)-:.d ~' (") :'51'/1 ~:\'_ I _U -< \V AUG 1 0 2004 f ERIC M. BERMAN, P.C. BY: Robert M. Kline, Esq. Attorney for Plaintiff Attorney # 56479 198 Allendale Road, Suite 306 King of prussia, P A 19406 (610) 265.7720 DISCOVER BANK c/o Eric M. Berman, P .C. 198 Allendale Road, Suite 306 King of prussia, P A 19406 COURT OF COMMON PLEAS CUMBERLAND COUNTY CIV1L ACTION LAW plaintiff CASE NO.: 04-2574 V. TRACEY E. GLESSNER ORDER This matter having been brought before the Court on motion of Robert M. Kline, attorney for Plaintiff, for an Order Allowing Alternative Service of the complaint by ordinary and certified mail, return receipt requested, and the Court having considered the matter and good cause appearing, AND NOW, to wit, this 11.~ dayof a1....s-- ,20 0<1 Plaintiff's Motion for Alternative Service is GRANTED. laintiffmay serve the Complaint upon Defendant by ordinary and certified mail, return receipt requested at 14 s. Broad Street Fl. 2 Mechanicsburg, P A 17055. The Complaint shall be deemed as served if the requirements of Pa.R.Civ.P .403, relating to service by mail, are met. BYT ;OURT: . / " rl~ J. ,o~ O~-\3 95 -~ ud -I.. ,.,;e. ;; J :J'iT 7fJDZ At"'~/!(\'..'.n:,! '''''!'.' -" . l(..!."'~:','Lil_;.\""'\.d .:.:dl :'OC:0fO-C97l:! '" :ill Our File No. 185303 ERIC M. BERMAN, P.C. By: Robert M. Kline, Esquire Identification No. 56479 500 N. Gulph Road, Suite 350 King of Prussia, P A 19406 (610) 265-7720 Attorneys for Plaintiff DISCOVER BANK c/o Eric M. Berman, P.C. 500 N. Gulph Road, Suite 350 King of Prussia, P A 19406 COURT OF tOMMON PLEAS CUMBERL~DCOUNTY CIVIL ACTIpN CASE NO.: ~4-2574 vs. TRACEY GLESSNER PRAECIPE TO REINSTATE COMPf-AINT TO THE PROTHONOTARY: Kindly reinstate the Complaint in the above matter. ERIC M. BERMAJ'f, P.C. By: I- Robert M. Kline, E$quire Attorneys for Plain~iff I Dated: July 26, 2006 g ~ ~ ;::: ~ -u,c ~ ~. ';2,"1'1 ~;J., c> S; - ~~ '0 ?e' e::> 9~ <: ." -0 :r::B 'J.-'"'C", ~~ ~2 :s: f.i! z: "'< :.l c::> ~ ..0 . Our File No. 185303 ATTORNEYS FOR PLAINTIFF ERIC M. BERMAN, P.C. BY: Eric M. Berman, Esquire, I.D. 83698 BY: Robert M. Kline, Esquire.I.D. 56479 500 North Gulph Road, Suite 350 King of Prussia, PA 19406 (610) 265-7720 -----------------------------------------X COURT OF COMMON PLEAS COUNTY OF CUMBERLAND DISCOVER BANK c/o ERIC M. BERMAN, P.C. 500 North Gulph Road, Suite 350 King of Prussia, PA 19406 TRIAL DIVISION CIVIL ACTION No. 04-2574 vs. TRACEY E GLESSNER -----------------------------------------x PRAECIPE TO ENTER DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter a default judgment in favor of Plaintiff, DISCOVER BANK, and against Defendant, TRACEY E GLESSNER , for failure to answer or otherwise respond to the Complaint - Civil Action. The Complaint was served upon Defendant on 08/23/2006, by the Sheriff's Office of COUNTY OF CUMBERLAND County. A copy of the Notice of Intention to Take Default served upon the Defendant by regular mail on / ~~,~~ is attached hereto as Exhibit B. ~)~0 /:5ICJ~ I certify that written notice of the intention to file this Praecipe was mailed or delivered to the party against whom judgment is to be entered after the default occurred and at least ten days prior to the date of the filing of this Praecipe. Copies are attached. R.C.P.237.1. Assess damages in the principal amount of $13,612.91, being the amount demanded in the Complaint, together with attorneys fees and court costs. ~ ~ ERIC M. BERMAN, P.C. Attorneys for Plaintiff By: Eric M. Berman, Esquire ERIC M. BERMAN, P.C. Attorneys for Plaintiff By: Robert M. Kline, Esquire SPACEJUB-ZH Our File No. 185303 ATTORNEYS FOR PLAINTIFF .. ERIC M. BERMAN, P.C. BY: Eric M. Berman, Esquire, I.D. 83698 BY: Robert M. Kline, Esquire,I.D. 56479 500 North Gulph Road, Suite 350 King of Prussia, PA 19406 (610) 265-7720 -----------------------------------------x COURT OF COMMON PLEAS COUNTY OF CUMBERLAND DISCOVER BANK c/o ERIC M. BERMAN, P.C. 500 North Gulph Road, Suite 350 King of Prussia, PA 19406 TRIAL DIVISION CIVIL ACTION vs. No. 04-2574 TRACEY E GLESSNER -----------------------------------------x NOTICE OF INTENTION TO TAKE DEFAULT JUDGMENT TO: TRACEY E GLESSNER 1437 APPLE CIR APT. A190 MECHANICSBURG, PA 17055-3705 DATE OF NOTICE: Y-~~~ I~~~~ IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAIILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS NOTICE TO YOUR LAWYER AT ONCE. IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORFD 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. COUNTY OF CUMBERLAND BAR ASSOCIATION 2 LIBERTY AVE. CARLISLE, PA 17013 800-990-9108 ~ ~ ERIC M. BERMAN, P.C. Attorneys for Plaintiff By: Robert M. Kline, Esquire / ERIC M. BERMAN, P.C. Attorneys for Plaintiff By: Eric M. Berman, Esquire SPACEJUD-ZH ,Our File No. 185303 ATTORNEYS FOR PLAINTIFF ERIC M. BERMAN, P.C. By: Eric M. Berman, Esquire, I.D. 8369 By: Robert M. Kline, Esquire,I.D. 5647 500 North Gulph Road, Suite 350 King of Prussia, PA 19406 (610) 265-7720 -----------------------------------------x COURT OF COMMON PLEAS COUNTY OF CUMBERLAND DISCOVER BANK c/o ERIC M. BERMAN, P.C. 500 North Gulph Road, Suite 350 King of Prussia, PA 19406 TRIAL DIVISION CIVIL ACTION vs. No. 04-2574 TRACEY E GLESSNER -----------------------------------------x CERTIFICATION OF NON-MILITARY SERVICE I am one of Plaintiff's attorneys and am authorized to make this certification on Plaintiff's behalf. The above named Defendant(s) is (are) over 18 years of age and reside at 1437 APPLE CIR APT. A190 , MECHANICSBURG, PA 17055 3705. The occupation of the Defendant(s) is (are) unknown. The Defendant(s) is (are) not in the Military Service of the United States, nor any State or Territory thereof or its allies as defined in the Soldiers' and Sailors' Civil Relief Act of 1940 and the amendments thereto. I verify that the statements made in the foregoing certification are true and correct to the best of my knowledge, information and belief, and I understand that the statements in said certification are made subject to the penalties of Pa.C.S. 4904 relating to unsworn falsification to authorities. ~ ~... ERIC M. BERMAN, ESQUIRE ATTORNEY FOR PLAINTIFF SPACEJUB-ZK ROBERT M. KLINE, ESQUIRE ATTORNEY FOR PLAINTIFF Our File No. 185303 ATTORNEYS FOR PLAINTIFF ERIC M. BERMAN, P.C. BY: Eric M. Berman, Esquire, I.D. 8369 BY: Robert M. Kline, Esquire.I.D. 5647 500 North Gulph Road, Suite 350 King of Prussia, PA 19406 (610) 265-7720 -----------------------------------------x COURT OF COMMON PLEAS COUNTY OF CUMBERLAND DISCOVER BANK c/o ERIC M. BERMAN, P.C. 500 North Gulph Road, Suite 350 King of Prussia, PA 19406 TRIAL DIVISION CIVIL ACTION vs. No. 04-2574 TRACEY E GLESSNER -----------------------------------------x CERTIFICATION OF ADDRESSES TO THE PROTHONOTARY: The address of the Plaintiff, Judgment Creditor, is c/o Eric M. Berman, P.C., 500 North Gulph Road, Suite 350, King of Prussia, PA 19406. The last known address of the Defendant, Judgment Debtor, is 1437 APPLE CIR APT. A190 , MECHANICSBURG, PA 17055 3705. ~. ~~ Eric M. Berman, P.C. Attorneys for Plaintiff By: Robert M. Kline, Esquire Eric M. Berman, P.C. Attorneys for Plaintiff By: Eric M. Berman, Esquire SPACEJUB-ZH ti - - ~ ~ t ~ V (:) ~ i.~ C> ~ -) \' ~ ~1? t ---- ....-' (} c:"::-' C fj~ ;2":"'" t'.' r-" <...-0 -- .,' ~. 1') c-. JI" Our File No. 185303 , ~ATTORNEYS FOR PLAINTIFF ERIC M. BERMAN, P.C. By: Eric M. Berman, Esquire, I.D. 83698 By: Robert M. Kline, Esquire,I.D. 56479 500 North Gulph Road, Suite 350 King of Prussia, PA 19406 (610) 265-7720 -----------------------------------------x COURT OF COMMON PLEAS COUNTY OF CUMBERLAND DISCOVER BANK c/o ERIC M. BERMAN, P.C. 500 North Gulph Road, Suite 350 King of Prussia, PA 19406 TRIAL DIVISION CIVIL ACTION vs. No. 04-2574 TRACEY E GLESSNER -----------------------------------------x TO: TRACEY E GLESSNER 1437 APPLE CIR APT. A190 MECHANICSBURG, PA 17055-3705 NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a JUDGMENT BY DEFAULT has been entered against you in the above proceeding and that enclosed herewith is a copy of all the (record) documents filed in support of the said JUDGMENT. IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ERIC M. BERMAN, P.C., Attorneys at Law. Attention: Eric M. Berman, Esquire, or Robert M. Kline, Esquire, at this telephone number. 1-610-265-7720. ~ Jfo'THO SHERIFF'S RETURN - REGULAR CASE NO: 2004-02574 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND DISCOVER BANK VS GLESSNER TRACEY E KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County, Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon GLESSNER TRACEY E the DEFENDANT , at 1842:00 HOURS, on the 23rd day of August , 2006 at 1437 APPLE CIRCLE APT 190 MECHANICSBURG, PA 17055 by handing to JSAON GLESSNER a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 10.56 .00 10.00 .00 38.56 I' q. Ji..\. 0(, q. "..i' ?": ,.'''' , . ? f~f:.(<:' R. Thomas Kline ,./-- ~ ~-~ ..-"";:/; ,/ ~':,.t..:~'_~f'.~.t:"" 08/24/2006 ERIC BERMAN of A.D. Sworn and Subscibed to By: before me this day