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HomeMy WebLinkAbout10-5079Our File No.: 275745 APOT14AKER & 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. CHARLENE A SHAFFER 71 N MIDDLETON RD CARLISLE, PA 17013-8644 Defendant. {_ c T 17 Y aolo ??lr S ??in a: Sa- C-l yfi r.ts COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: I(.)- SWf ??vi 1? 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 O OA.oo Po Arn` C it Igaa8d 0apt&"A Our File No.: 275745 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothatker, Esquire Attorney I.D. #38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff 01NUUVER BANK BY ITS SERVICING AGENT DFS SERVICES, LLC 6500 NEW ALBANY ROAD NEW ALBANY, OH 43054 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. Plaintiff, VS. CHARLENE A SHAFFER 71 N MIDDLETON RD CARLISLE, PA 17013-8644 Defendant. 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 CHARLENE A SHAFFER, an adult individual residing at 71 N MIDDLETON RD CARLISLE, PA 17013-8644. 3. At the special instance and request of Defendant, Plaintiff, DISCOVER BANK BY ITS SERVICING AGENT DFS SERVICES, LLC, issued to Defendant(s), Account # ending in 5235. 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 $7,908.29. 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 $7,908.29 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIA ES, P.C. Attorney for Plaint A Law Firm Engaged in D 96t Collection BY: David J. Apo h cer, uire Dated: 7/28/2010 Our File No.: 275745 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, and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904/eVting to unworn falsification to authorities. David J. Apo r, Esquire Attorney for Pl tiff DATE: 7/28/2010 DISCOVER BANK BY ITS SERVICING AGENT DFS SERVICES, LLC CHARLENE A SHAFFER 71 N MIDDLETON RD CARLISLE, PA 17013-8644 STATEMENT OF ACCOUNT Debtor's Name: CHARLENE A SHAFFER Account Number: ending in 5235 Balance Due: $7,908.29 Our File No.: 275745 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor Discover Bank vs. Charlene A. Shaffer ~$~~,tr of `u~tbrr/~'~ ;~s~ . ?~ _.. _ ~~-.~~ <?Ff SCE C7F ' HE SN~RIFF r:. ~_, t~ 7v' 2~ ~ ~ ~ ~.~'u I ~ ~-,r~1; ~ i ~qp AvG 1~ ~ c1= t1 r Lam, ,'.i.,r r •`( ' r Case Number 2010-5079 SHERIFF'S RETURN OF SERVICE 08/13/2010 09:10 PM -Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on August 13, 2010 at 2110 hours, she served a true copy of the within Complaint and Notice, upon the within name defendant, to wit: Charlene A. Shaffer, by making known unto Charlie Shaffer, Husband of defendant at 71 North Middleton Road, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the s m VALERIE WEARY, DEPU SHERIFF COST: $33.40 August 16, 2010 SO ANSWERS, .,, ~1~, ~-.,.., RON R ANDERSON, SHERIFF (c) CountySuite Shenfi, Teleosott, Inc. Our File No.: 275745 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 BY ITS SERVICING AGENT DFS SERVICES, LLC vs. Plaintiff, i t_~!J°'~ ~ ICS. t.1F Tl``1,. ~'i;~ TNT€~OTARY 2u10 ACT - l P~ ~~ ~ ~ ~~~~~~~~~~~~ c©u~a~~r ~'~~~SYLV~~IA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-5079 CIVIL TERM CHARLENE A SHAFFER Defendant. PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & A Law Firm .TES, P.C. Debt By: David J. Apothaker, Esquire Dated: 9/22/2010 111111111111111