HomeMy WebLinkAbout10-3699
Our File No.: 254587
APOTHAKER & ASSOCIATES, P.C.
BY: David J. Apothaker, Esquire
Attorney I.D. #38423
520 Fellowship Road C306
Mount Laurel, NJ 08054
(800) 672-0215
Attorneys for Plaintiff
DISCOVER BANK BY ITS SERVICING
AGENT DFS SERVICES LLC
6500 NEW ALBANY ROAD
NEW ALBANY, OH 43054
Plaintiff,
vs.
JEREMY T KOPINETZ
708 WERTZVILLE RD
ENOLA, PA 17025-2037
Defendant.
Fl
')E7 THE f' :1%py
2010 JUN -7 AFt 8: U7
Fc NN',YLVAtiiA
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: 0- 2L4p eok-il
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
34 S. BEDFORD ST.
CARLISLE PA 17013
717-249-3166
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Our File No.: 254587
APOTHAKER & ASSOCIATES, P.C.
BY: David J. Apothaker, Esquire
Attorney I.D. #38423
520 Fellowship Road C306
Mount Laurel, NJ 08054
(800) 672-0215
Attorneys for Plaintiff
DISCOVER BANK BY ITS SERVICING
AGENT DFS SERVICES LLC
6500 NEW ALBANY ROAD
NEW ALBANY, OH 43054
Plaintiff,
vs.
JEREMY T KOPiNETZ
708 WERTZVILLE RD
ENOLA, PA 17025-2037
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO..
CIVIL ACTION COMPLAINT
FIRST COUNT
1. Plaintiff is DISCOVER BANK BY ITS SERVICING AGENT DFS SERVICES LLC, 6500
NEW ALBANY ROAD, NEW ALBANY, OH 43054.
2. Defendant(s) is/are JEREMY T KOPINETZ, an adult individual residing at 708 WERTZVILLE
RD ENOLA, PA 17025-2037.
3. At the special instance and request of Defendant, Plaintiff, DISCOVER BANK BY ITS
SERVICING AGENT DFS SERVICES LLC, issued to Defendant(s), Account #6011298894246937.
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 $6,676.36. 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
$6,676.36 and requests this Court award costs to the extent permitted by applicable law.
APOTHAKER g4SOCIATES, P.C.
A Law Firm ErJgagkd in I)e6t Collection
BY:
David J. Apothaker, Esquire
Dated: 5/28/2010
Our File No.: 254587
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 Pa.C.S.A/404 relating to unworn falsification to authorities.
David J. othaker, Esquire
Attorney or Plaintiff
DATE: 5/28/2010
DISCOVER BANK BY ITS SERVICING AGENT DFS SERVICES LLC
JEREMY T KOPINETZ
708 WERTZVILLE RD
ENOLA, PA 17025-2037
STATEMENT OF ACCOUNT
Debtor's Name: JEREMY T KOPINETZ
Account Number: 6011298894246937
Balance Due: $6,676.36
Our File No.: 254587
EXHIBIT "A"
254587
Request for Service
R. Thomas Kline Sheriff
Cumberland County Office of the Sheriff
One Courthouse Square
Carlisle, PA 17013
Ph: 717.240.63 90
Fx: 717-240-6397
Plaintiff/s: Court Number:
DISCOVER BANK BY ITS Expiration Date:
SERVICING AGENT DFS SERVICES
LLC
Type of Action:
Civil Action
Defendants:
JEREMY T KOPINETZ
Serve Upon:
JEREMY T KOPINETZ
Address for Service:
708 WERTZVILLE RD
ENOLA, PA 17025-2037
Alternate Address for Service:
Type of Service:
( ) Personal (X) Adult in Charge O Deputize O Certified Mail O Posting
Special Service Instructions:
* * If service is to be made by deputized service to another county please specify which
county
Filing Attorney Information:
Name: Apothaker & Associates, P.C.
Address: 520 Fellowship Road C306
Mount Laurel, NJ 08054
Telephone: 215-634-8920
SHERIFF'S OFFICE OF CUMBERLAND COUNTY
Ronn R Anderson ~~`~~ ~' ::I` ~
Sheriff ' ~~ ~~ l~s,r: ~r'~ ~ ~-rAE~y
Jody S Smith ~~~kw,c~ at ~,ur,t~err~j'~ ZO~~ ~~~~ _9
Chief Deputy ~~ ~' ~ ~
'~-,.
Richard W Stewart C~~~~~ - .. y ~t ,
Solicitor c~~~,~F ,, ~ ;..~=~,r`~ ~, ',~;- , ' `-,...UI1~
r~f1;,~, (,ifr,"~i~~
Discover Bank Case Number
vs. 2010-3699
Jeremy T. Kopinetz
SHERIFF'S RETURN OF SERVICE
06/07/2010 05:20 PM -Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on June
7, 2010 at 1716 hours, she served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Jeremy T. Kopinetz, by making known unto himself personally, at 708 Wentzville Road,
Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him
personally the said true and correct copy of the same.
MICHEL TSHALL, DEPUTY
SHERIFF COST: $41.50
June 08, 2010
SO ANSWERS,
RON R ANDERSON, SHERIFF
!cj Goun'vS~ito Sn~,iff, Tele~so`t. In;;_
Our File No.: 25458' ~ r
APOTHAKER & ASSOCIATES, P.C.
By: David J. Apothaker
Attorney I.D.# 38423
520 Fellowship Road C306
Mount Laurel, NJ 08054
(800)672-0215
Attorney for Plaintiff
DISCOVER BANK BY ITS SERVICING
AGENT DFS SERVICES LLC
Plaintiff
vs.
JEREMY T KOPINETZ
Defendant
2~1~ Jt~! 2.5 ~~~~~ ~~~ ~7
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
NO.: 2010-3699
Civil Action
PRAECIPE FOR DEFAULT JUDGMENT
TO THE PROTHONOTARY:
Kindly enter judgment against Defendant, JEREMY T KOPINETZ, in the default of an
Answer, in the amount of $6,676.36 computed as follows:
Amount claimed in complaint: $ 6,676.36
Less: Amount Paid: ( 0.00)
Plus: Interest from May 28, 2010 to July 15, 2010
at the legal interest rate of 0.00% per annum 0.00
Attorney fees 0.00
TOTAL // $ 6,676.36
I certify that Defendant, JEREMY T KOPINETZ, l~st~nown address is 708
WERTZVILLE RD ENOLA, PA 17025-2037. / / /
Dated: July 15, 2010
David J.
Attorney
Esq.
l~.oo PQ A~
C~- Igoa.i'1
~,~'a~s~r8l
r
~(o~~, ~~
OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
TO: JEREMY T KOPINETZ
708 WERTZVILLE RD
ENOLA, PA 17025-2037
DISCOVER BANK BY ITS SERVICING
AGENT DFS SERVICES LLC
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
Plaintiff
vs.
JEREMY T KOPINETZ
Defendant
NOTICE
NO.: 2010-3699
Civil Action
Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you aze hereby notified that a
Judgment has been entered against you in the above proceeding as indicated below.
XX JUDGMENT BY DEFAULT
JUDGMENT IN REPLEVIN
JUDGMENT BY CONFESSION
JUDGMENT FOR POSSESSION
JUDGMENT ON AWARD OF ARBITRATORS
JUDGMENT ON VERDICT
JUDGMENT ON COURT FINDINGS
JUDGMENT ON WRIT OF REVIVAL
IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL:
ATTORNEY David J. A othaker• Esa• at this telephone number: 800-672-0215
y/6t~v/lD
Our File No.: 254587
APOTHAKER & ASSOCIATES, P.C.
By: David J. Apothaker
Attorney I.D.# 38423
520 Fellowship Road C306
Mount Laurel, NJ 08054
(800)672-0215
Attorney for Plaintiff
DISCOVER BANK BY ITS SERVICING
AGENT DFS SERVICES LLC
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
Plaintiff
vs.
JEREMY T KOPINETZ
Defendant
NO.: 2010-3699
Civil Action
CERTIFICATION PURSUANT TO RULE 237.1
Pursuant to PA Rule Civil Procedure 237.1, I certify that a copy of the NOTICE OF
PRAECIPE TO ENTER JUDGMENT BY DEFAULT has been sent to the Defendant or the
Attorney of Record.
I verify that the statements made in this Certification are true and correct. I understand
that false statements herein are made subject to the penalti 18 Pa.C.S.A. §4904, relating to
unsworn falsification to authorities.
David J. Apo r, Esq.
Attorney for Plaintiff
Dated: July 15, 2010
Our File No.: 254587
APOTHAKER & ASSOCIATES, P.C.
By: David J. Apothaker
Attorney I.D.# 38423
520 Fellowship Road C306
Mount Laurel, NJ 08054
(800) 672-0215
Attorney for Plaintiff
DISCOVER BANK BY ITS SERVICING
AGENT DFS SERVICES LLC
Plaintiff
vs.
JEREMY T KOPINETZ
Defendant
military
AFFIDAVIT OF NON-MILITARY SERVICE
COMMONWEALTH OF PENNSYLVANIA
COUNTY OF CUMBERLAND
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
NO.: 2010-3699
. SS.
David J. Apothaker, being duly sworn according to law, deposes and -says that I am the
attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 708
WERTZVILLE RD ENOLA, PA 17025-2037.
We inquired with the web site of the Defense
Wilson Boulevard, Suite 400, Arlington, VA 22205
branch of the military.
Mary M. Snavely-Dixon, Director of the De
our inquiry indicated that the Defendant(s) is/are not
Civil Action
wer Data Center, located at 1600
if the Defendant(s) is/are in any
Center has sent back
David J. Apothaker, Esq.
Attorney for Plaintiff
I verify that the statements made in this Certification are true and correct. I understand
that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to
unsworn falsification to authorities.
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254587 OFFICE OF THE PROTHONOTARY
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DISCOVER BANK' BY ITS SERVICING AGENT )COURT OF COMMON PLEAS
DFS SERVICES LLC )CUMBERLAND COUNTY
vs. )
N0.2010-3699
JEREMY T KOPINETZ )
To: JEREMY T KOPINETZ
708 WERTZVILLE RD
ENOLA, PA 17025-2037
IMPORTANT NOTICE
YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED 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 PAPER 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 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
ASSOCIATION
34 S. BEDFORD ST.
CARLISLE, PA 17013
717-249-3166
Date: June 30, 2010
BAR
DAVID J. AP T R, ESQUIRE
APOTHAKER & ASSOCIATES, PC
A Law Firm Engaged in Debt Collection
520 Fellowship Road C306
Mount Laurel, NJ 08054
(800) 672-0215
Attorney for Plaintiff
Attorney ID #38423
DISCOVER BANK BY ITS SERVICING
AGENT DFS SERVICES, LLC,
Plaintiff
V.
JEREMY T KOPINETZ,
Defendant
*010000A 'q2t
INOW
IN THE COURT OF COMMON PLEAS OF
THE NINTH JUDICIAL DISTRICT
No. 2010-3699 CIVIL TERM
IN RE: MOTION TO AMEND CAPTION
RULE TO SHOW CAUSE
AND NOW, this day of March, 2012, upon consideration of Plaintiff's
Motion to Amend Caption, a Rule is issued upon Defendant to show cause why Plaintiff
should not be afforded leave of court to amend the caption to reflect the proper name
of the Plaintiff as Discover Bank.
RULE RETURNABLE within 20 days from the date of service of this Rule.
By the Court,
Thomas A. 4cey C.P.J.
Distribution List:
d? Benjamin J. Cavallaro, Esq.
Apothaker & Associates
520 Fellowship Road C306
Mount Laurel, NJ 08054
For Plaintiff
v" Jeremy T. Kopinetz
708 Wertzville Rd
Enola, PA 17025-2037
Defendant, pro se
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Our File No.: 254587
APOTHAKER & ASSOCIATES, P.C.
By: Benjamin J. Cavallaro, Esquire
Attorney I.D. #307949
520 Fellowship Road C306
Mount Laurel, NJ 08054
(800) 672-0215
Attorneys for Plaintiff
DISCOVER BANK BY ITS SERVICING
AGENT DFS SERVICES LLC
Plaintiff
vs.
JEREMY T KOPINETZ
Defendant
Civil Action
PRAECIPE TO WITHDRAW MOTION TO AMEND CAPTION
TO THE PROTHONOTARY:
Kindly withdraw Plaintiff's Motion to Amend Caption.
APOTHAKER & ASSOCIATES, P.C.
Attorney for Plaintiff
A Law Firm Engaged in Debt Collection
BY: _
Benja in J. avallaro, Esquire
ty
Nfis f VFh tilp,
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
NO.: 2010-3699
Dated: May 15, 2012
Our File No.: 254587
APOTHAKER & ASSOCIATES, P.C.
By: Benjamin J. Cavallaro, Esquire
Attorney I.D. #307949
520 Fellowship Road C306
Mount Laurel, NJ 08054
(800) 672-0215
Attorneys for Plaintiff
DISCOVER BANK BY ITS SERVICING
AGENT DFS SERVICES LLC
Plaintiff
vs.
JEREMY T KOPINETZ
Defendant
?1 Li lrV IRY ?•\
li dda
G 12 JUL 20 p14
C"BEXAtia
PINNSYLVANIA
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
NO.: 2010-3699
Civil Action
MOTION TO AMEND CAPTION
On or about May 28, 2010 our firm filed a Civil Action Complaint captioned
DISCOVER BANK BY ITS SERVICING AGENT DFS SERVICES LLC vs. JEREMY T
KOPINETZ.
2. The Plaintiff changed its name to DISCOVER BANK.
3. The correct name for the Plaintiff should be DISCOVER BANK.
4. Accordingly, the Plaintiff now respectfully petitions the Court to allow Plaintiff to
Amend the caption to reflect the proper name of the Plaintiff, DISCOVER BANK.
5. The Pennsylvania Rules of Civil Procedure, Pa.R.C.P. 1033, specifically
permit parties to amend their pleadings:
A party, either by filed consent of the adverse party or by leave of court, may at
any time change the form of action, correct the name of a party or amend his
pleading. The amended pleading may aver transactions or occurrences which
have happened before or after the filing of the original pleading, even though they
give rise to a new cause of action or defense. An amendment may be made to
conform the pleading to the evidence offered or admitted.
6. Defendant's rights will not be prejudiced by this change.
7. A Judge has not ruled upon any other issue in the within motion. The Defendant
consents to having the Motion heard on the Briefs.
WHEREFORE, Plaintiff requests this court to enter an Order granting leave to amend
Plaintiff's Complaint.
APOTHAKER & ASSOCIATES, P.C.
Attorney for Plaintiff
A Law Firm Engaged in Debt Collection
BY:
Benjam'n J. Cap allaro, Esquire
Our File No.: 254587
APOTHAKER & ASSOCIATES, P.C.
By: Benjamin J. Cavallaro, Esquire
Attorney I.D. #307949
520 Fellowship Road C306
Mount Laurel, NJ 08054
(800) 672-0215
Attorneys for Plaintiff
DISCOVER BANK BY ITS SERVICING
AGENT DFS SERVICES LLC
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
Plaintiff
vs.
JEREMY T KOPINETZ
Defendant
NO.: 2010-3699
Civil Action
BRIEF IN SUPPORT OF PLAINTIFF'S
MOTION TO AMEND CAPTION
Plaintiff, DISCOVER BANK BY ITS SERVICING AGENT DFS SERVICES LLC filed suit
against Defendant on or about May 28, 2010. Plaintiff requests that this Court enter an Order
allowing Plaintiff to amend the caption hereto pursuant to Pa.R.C.P. No. 1033.
WHEREFORE, DISCOVER BANK BY ITS SERVICING AGENT DFS SERVICES LLC,
respectfully requests this Honorable Court grant Plaintiff's Motion to Amend Caption.
APOTHAKER & ASSOCIATES. P.C.
Attorney for Plaintiff
A Law Firm Engaged in Debt Collection
BY:
Benja in J. Ca allaro, Esquire
Our File No.: 254587
APOTHAKER & ASSOCIATES, P.C.
By: Benjamin J. Cavallaro, Esquire
Attorney I.D. #307949
520 Fellowship Road C306
Mount Laurel, NJ 08054
(800) 672-0215
Attorneys for Plaintiff
DISCOVER BANK BY ITS SERVICING
AGENT DFS SERVICES LLC
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
Plaintiff
vs.
JEREMY T KOPINETZ
Defendant
CERTIFICATION OF SERVICE
Civil Action
I, Benjamin J. Cavallaro, Esquire, attorney for Plaintiff, certify that on July 18, 2012, I
caused to be served a copy of Plaintiff's Order, Motion to Amend Caption, and Brief in support
thereof by mail on:
JEREMY T KOPINETZ
708 WERTZVILLE RD
ENOLA. PA 17025-2037
APOTHAKER & ASSOCIATES, P.C.
Attorney for Plaintiff
A Law Firm Engaged in Debt Collection
NO.: 2010-3699
BY: !
Benjamin J. Cap allaro, Esquire
APOTHAKER& ASSOCIATES, P.C.
ATTORNEYS AT LAW
June 12, 2012
JEREMY T KOPINETZ
708 WERTZVILLE RD
ENOLA, PA 17025-2037
RE: DISCOVER BANK BY ITS SERVICING AGENT DFS SERVICES LLC
v JEREMY T KOPINETZ
DOCKET NO.: 2010-3699
OUR FILE NO: 254587
DEAR JEREMY T KOPINETZ
We would like the attached Motion to Amend Caption to be decided on the
papers. Kindly advise if you consent to same. If we do not hear from you within twenty
(20) days to the contrary., we will assume that you consent.
Very truly yours,
APOTHAKER & ASSOCIATES, P.C.
Benjamin J. Cavallaro, Esquire
/TJ
This firm is a debt collector. We are attempting to collect a debt and any information
obtained will be used for the purpose of collecting the debt.
520 Fellowship Road C306, Mt. Laurel, NJ 08054
800 672.0215 800 757.4928f
856 780.1000 856 780.10201'
215 634.8920 215 634.8421f
DISCOVER BANK BY ITS SERVICING
AGENT DFS SERVICES, LLC,
Plaintiff
V.
JEREMY T KOPINETZ,
Defendant
IN THE COURT OF COMMON PLEAS OF
THE NINTH JUDICIAL DISTRICT
No. 2010-3699 CIVIL TERM
IN RE: MOTION TO AMEND CAPTION
RULE TO SHOW CAUSE
AND NOW, this 24th day of July, 2012, upon consideration of Plaintiff's Motion
to Amend Caption, filed July 20, 2012,1 a Rule is issued upon Defendant to show cause
why Plaintiff should not be entitled to amend the caption to reflect the proper name of
the Plaintiff as Discover Bank.
RULE RETURNABLE within 20 days from the date of service of this Rule.
Benjamin J. Cavallaro, Esq.
Apothaker & Associates
520 Fellowship Road C306
Mount Laurel, NJ 08054
For Plaintiff
?Jeremy T Kopinetz
708 Wertzville Rd.
Enola, PA 17025-2037
Defendant, pro se
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' this ethe second of such motions filed by Plaintiff in the instant matter. Plaintiff withdrew the prior motion
before the court's resolution on the merits.
By the Court,
Thomas A. Placey, C. P.J.
Our File No.: 254587
APOTHAKER & ASSOCIATES, P.C.
By: Benjamin J. Cavallaro, Esquire
Attorney LD. #30799
520 Fellov~tship Road C306
Mount Law•el, N.108054
(800) 672-0215
Attorneys for Plaintiff
DISCOVER BANK BY ITS SER~JICING
AGENT DFS SERVICES LLC
Plaintiff
vs.
JEREMY ~~ KOPINETZ
Defendant
COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY
NO.: 2010-3699
Civil Action
AMENDED MOTION TO MAKE RULE ABSOLUTE
1. Plaintiff filed a Motion to Amend Caption on .July 20, 2012.
2. The rule returnable date fox' said petition was October 3, 2012.
~. Plaintiff served the petition and corresponding rule to show cause on
defendant/defense counsel on September 12, 2012 by mail.
4~ To date, na response has been filed by defendant.
5. The concurrence of any opposing counsel of record was sought and could not be
obtained.
6. No judge has ruled on any other issue in this matter or any related matters.
7. Plaintiff requests that this Court enter an Order making the Rule Absolute.
WHEREFORE. Plaintiff, DISCOVER BANK BY ITS SERVICING AGENT' DFS
SERVICES LLC, respectfully requests this Honorable Court enter an Order making the Rule
Absolute.
APOTI-TAKER & ASSOCIATES, P.C.
Attorney for Plaintiff
A Law :Firm Engaged in Debt Collection
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BY: _ _ _
Benjaman .. C vallaro, Esquire
DISCOVER BANK BY ITS SERVICING
AGENT DFS SERVICES LLC,
Plaintiff
v.
JEREMY T. KOPINETZ,
Defendant
D~
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IN THE COURT OF COMMON PLEAS
OF THE NINTH JUDICIAL DISTRICT
2010-03699 -CIVIL TERM
IN RE: AMENDED MOTION TO MAKE RULE ABSOLUTE
ORDER OF COURT
AND NOW, this 20th day of November 2012, upon consideration of the
Amended Motion to Make Rule Absolute, and it appearing that Defendant has failed to
file a response of record, despite a Rule being issued on 24 July 2012, directing
Defendant to file such a response, Plaintiff's Amended Motion is GRANTED.
Distribution List:
Thomas A. Placey C.P.J.
/ Benjamin J. Cavallaro, Esq.
520 Fellowship Road C306
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Mount Laurel, NJ 08054
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