The URL can be used to link to this page

Home My WebLink About10-5081SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson =I_E_;`_ Sheriff ~~,tr mt £~ta-Ge~,~ - - ~ r:' Jody S Smith ~ ~~ ~ ~ ° +~ _ , 2QIO ~ i~ ~ ~ ~ ~; Chief Deputy ~, ; ~ ; i Richard W Stewart • x_1': ~o~o A~VG I~ p~ ~ ~3~p Solicitor S4Cf nF 'HE wnERIFF , ~, LUia ~" _. J; v 1 \, f' i_. Discover Bank Case Number vs. 2010-5081 Rosann S. Faust SHERIFF'S RETURN OF SERVICE 08/09/2010 08:30 PM -Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on August 9 2010 at 2030 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Rosann S. Faust, by making known unto herself personally, at 4 Rockledge Court, Carlisle, Cumberland County,:, Pennsylvania 17015 its contents and at the same time handing to her personally the said true and oorrect copy of the same. / ~~ C~~~ .. VALERIE WEARY, DEPUTY SHERIFF COST: $33.40 August 10, 2010 SO ANSWERS, •, -. RON R ANDERSON, SHERIFF (c) County Suite Sheriff, TeleosoR, Inc. Our file No.: 275527- J APOTHAKER & ASSOCI, 520 Fellowsiup Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff Attorney ID# 307949 FILED-OFFICE OF TI'Ile PRDTI ONOTAR ?IT` t UMBERLAI D COUNTY PEN11SY_VA141A DISCOVER BANK BY ITS SERVICING AGENT DFS SERVICES, LLC Plaintiff, vs. ROSANN S FAUST e !ICS -po>a //, COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 10-5081-CIVIL TERM Civil Action STIPULATION IN LIEU OF JUDGMENT Defendant. The matters and things in controversy having been discussed by and between the parties, and a settlement having been agreed upon: It is on September 13, 2010, STIPULATED by and between Plaintiff, DISCOVER BANK BY ITS SERVICING AGENT DFS SERVICES, LLC, and Defendant, ROSANN S FAUST parties as follows: 1. Defendant agrees to pay the sum of $13,594.97, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. The sum aforesaid of $13,594.97 shall be paid by the by Defendant, ROSANN S FAUST, to the attorneys for Plaintiff in the following manner: a. $380.00 due on or before the 24th day of each month, beginning September 24, 2010 thru December 24, 2010; b. $200.00 due on or before the 24th day of each month, beginning January 24, 2011 thru April 24, 2011; c. $380.00 due on or before the 24th day of each month, beginning May 24, 2011 thru December 24, 2011; d. $200.00 due on or before the 24th day of each month, beginning January 24, 2012 thru April 24, 2012; e. $380.00 due on or before the 24th day of each month, beginning May 24, 2012 thru December 24, 2012; Our file No.: 275527 f. $200.00 due on or before the 24th day of each month, beginning January 24, 2013 thru April 24, 2013 g. $380.00 due on or before the 24th day of each month, beginning May 24, 2010 that July 13, 2013; h. $2,454.97 due on or before August 24, 2013. All checks are to made payable to DISCOVER BANK BY ITS SERVICING AGENT DFS SERVICES, LLC, and sent to: Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 3. In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation, then, and in that event, Plaintiff shall be entitled to obtain the entry of Judgment against Defendant ex parte, in the sum of $13,594.97, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. 4. In the event of default as aforesaid, Plaintiff shall be entitled to obtain the entry of Judgment upon ex parte application, with supporting certification, and with notice to Defendant only in the form of a copy of the application addressed to ROSANN S FAUST by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plaintiff A Law Firw-4nRaaed ei Debt Collection By: ' Cavallaro, Esquire ROSANN S FAUST DISCOVER BANK BY ITS SERVICING AGENT DFS SERVICES, LLC, Plaintiff V. ROSANN S FAUST, Defendant IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT No. 2010-5081 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. Distribution List: s? Benjamin J. Cavallaro, Esq. Apothaker & Associates 520 Fellowship Road C306 Mount Laurel, NJ 08054 .y For Plaintiff rn = z Rosann S. Faust x 4 Rockledge Ct Carlisle, PA 17015-9190 x>c? zc, {-, Defendant, pro se -a a `. C 4 `CS IK4. I-e?? tey Our File No.: 275527 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. ROSANN S FAUST 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 En2aeed in Debt Collection BY: Benj in J. avallaro, Esquire s, }TIC iv0T; t: ;Y 2 I P#1 3 >';P?SY! X1;41 P COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-5081-CIVIL TERM Dated: May 15, 2012 Our File No.: 275527 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. ) ROSANN S FAUST ) Defendant HOTHONG'FAF? "'2 JUL 24 Qtf 3: 03 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-5081-CIVIL TERM Civil Action MOTION TO AMEND CAPTION 1. On or about July 28, 2010 our firm filed a Civil Action Complaint captioned DISCOVER BANK BY ITS SERVICING AGENT DFS SERVICES, LLC vs. ROSANN S FAUST. 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 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 am nd Plaintiff's Complaint. APOTHAKER & ASSOCIATES, P.C. Attorney for Plaintiff A Law Firm Engaged in Debt Collection BY: , Esquire Our File No.: 275527 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. ) ROSANN S FAUST ) Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-5081-CIVIL TERM Civil Action BRIEF IN SUPPORT OF PLAINTIFF'S MOTION TO AMEND CAPTION Plaintiff, DISCOVER BANK BY ITS SERVICING AGENT DFS SERVICES, LLC filed t against Defendant on or about July 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, LL?,, I 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: CY Benjami J. Ca Ilaro, Esquire Our File No.: 275527 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. ) ROSANN S FAUST ) Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-5081-CIVIL TERM Civil Action CERTIFICATION OF SERVICE I, Benjamin J. Cavallaro, Esquire, attorney for Plaintiff, certify that on July 18, 2012, 1 caused to be served a copy of Plaintiff's Order, Motion to Amend Caption, and Brief in thereof by mail on: ROSANN S FAUST 4 ROCKLEDGE CT CARLISLE, PA 17015-9190 APOTHAKER & ASSOCIATES, P.C. Attorney for Plaintiff A Law Firm Engaged in Debt Collection BY: Benja in J. Ca allaro, Esquire DISCOVER BANK BY ITS SERVICING AGENT DFS SERVICES, LLC, Plaintiff V. ROSANN S FAUST, Defendant W00406"Of 019 "At% 4& IN THE COURT OF COMMON PLEAS THE NINTH JUDICIAL DISTRICT No. 2010-5081 CIVIL TERM IN RE: MOTION TO AMEND CAPTION RULE TO SHOW CAUSE AND NOW, thisl j? day of August, 2012, upon consideration of Pla Motion to Amend Caption, filed July 24, 2012,1 a Rule is issued upon Defendant to cause why Plaintiff should not be entitled to amend the caption to reflect the prol name of the Plaintiff as Discover Bank. RULE RETURNABLE within 20 days from the date of service of this Rule. B Thomas . Placey, C.P.J. Benjamin J. Cavallaro, Esq. Apothaker & Associates 520 Fellowship Road C306 Mount Laurel, NJ 08054 For Plaintiff r ?Rosann S. Faust 4 Rockledge Ct z, Carlisle, PA 17015-9190 Defendant,/ ?pro se (a4 /?,/ 0?eS mad d Aevz- ' This is the second of such motions filed by Plaintiff in the instant matter. Plaintiff withdrew the prior motion before the court's resolution on the merits. 1-1 f`} Our file No.: 275527 APOT1-TAKER & ASSOCIATES, P'.C. By: Benjamin J. Cavallaro, Esquire Attorney I.D. #307949 520 Fellowship Road C306 Mount Laureh N3 08054 (804} ~TZ-0215 Attorneys for Plaintiff DISCOVER BANK BY ITS SERVICING AGENT DFS SERVICES, LLC Plaintiff vs. ROSANN S FAUST Defendant COURT OF COMMON PLL;AS OF CUMBERLAND COiJNTY NO.: 10-5081-CIVIL TERM Civil Action AMENDED MOTION TO MAKE RULE ABSOLUTE 1. Plaintiff filed a Motion to Amend Caption on July 24, 2012. 2. The rule returnable date for said petition was October 3, 20I 2. ~. Plaintiff served the petition and corresponding rule to show cause on defendant/defense counsel on September l2. 2012 by mail. 4. "[~o date. no response has been filed by defendant. 5. The concurrence of any ohposing 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 mattez-s. 7. Plaintiff requests that this Court enter an Order making the Rule .Absohrte. WHEREFORE, Plaintiff, DISCOVER BANK BY ITS SERVICING AGENT DFS SERVICES. LLC, respectfully requests this Honorable Court enter an Order makinb the Rule Absolute APOTHAKER & ASSOCIATES, P.C. Attorney for Plaintiff A Law Firm En din Debt Collection ~~ BY: ~ _ .,,. Benjamin J. Cavall:aro, Esquire DISCOVER BANK BY ITS SERVICING AGENT DFS SERVICES LLC, Plaintiff v. ROSANN S. FAUST, Defendant D~ ~~, IN THE COURT OF COMMON PLEAS OF THE NINTH JUDICIAL DISTRICT 2010-05081 -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 2 August 2012, directing Defendant to file such a response, Plaintiff's Amended Motion is GRANTED. Distribution List: BY T , Thomas A. I cey C.P.J. Benjamin J. Cavallaro, Esq. 520 Fellowship Road C306 Mount Laurel, NJ 08054 r~ ,.,, f-r ~ -~ 3 ,.~,., ._.. --, / Rosann S. Faust rnw ~ °"' .T.~ ;-~__ 4 Rockledge Court ~~ "~ ~_;~,-} ` ' Carlisle, PA 17015-9190 ~~ o ~ ~ r~ ~~.> . -_ -~-., ~..::Itl~w ~ ~J ~~ L ~a ~~~ Our File No.: 275527 r w *- APOTHAKER&ASSOCIATES, P.C. r,� i TA ii Kimberly F. Scian, Esquire i�"-�r `'' - ii Attorney I.D. #55140 3 M R 22 520 Fellowship Road C306 �� UtfERLANO COUNTY Mount Laurel,NJ 08054 PENNSYLVANIA (800) 672-0215 Attorneys for Plaintiff COURT OF COMMON PLEAS OF DISCOVER BANK ) CUMBERLAND COUNTY Plaintiff ) vs. ) NO.: 10-5081-CIVIL TERM ROSANN S FAUST ) Civil Action Defendant ) MOTION FOR LEAVE OF COURT TO FILE AMENDED STIPULATION 1. Plaintiff, DISCOVER BANK, filed suit against Defendant on or about July 28, 2010. 2. The parties settled this matter and filed a Stipulation in Lieu of Judgment with the court memoralizing the terms of the settlement agreement. 3. Subsequent to the settlement and outside of plaintiff s counsel participation, the CFPB, FDIC and Plaintiff, Discover Bank, agreed to issue a credit on this account. 4. This agreement necessitates the filing of an Amended Stipulation to reflect a credit of $229.35 dollars to the existing charged off account balance. 5. This credit adjustment inures to the benefit of the consumer. 6. Plaintiff requests that this Court enter an Order allowing Plaintiff to file the Amended Stipulation attached hereto and incorporated by reference herein. WHEREFORE, Plaintiff, DISCOVER BANK, respectfully requests this Honorable Court grant Plaintiff s Motion for Leave of Court to file Amended Complaint. APOTHAKER&ASSOCIATES,P.C. Attorney for Plaintiff A Law Firm Engaged i e Collection Y: K m ely F. Scian, Esquire Our File No.: 275527 APOTHAKER& ASSOCIATES, P.C. By: Kimberly F. Scian, Esquire Attorney I.D. #55140 520 Fellowship Road C306 Mount Laurel,NJ 08054 (800) 672-0215 Attorneys for Plaintiff COURT OF COMMON PLEAS OF DISCOVER BANK ) CUMBERLAND COUNTY Plaintiff ) VS. ) NO.: 10-5081-CIVIL TERM ROSANN S FAUST ) Civil Action Defendant ) BRIEF IN SUPPORT OF PLAINTIFF'S MOTION FOR LEAVE OF COURT TO FILE AMENDED STIPULATION Plaintiff, DISCOVER BANK, filed suit against Defendant on or about July 28, 2010. Subsequent to the filing of the original complaint and stipulation, plaintiff, Discover Bank agreed to issue a credit on this account. Pursuant to an agreement with the CFPB and FDIC, Discover Bank wishes to amend the stipulation to reflect a credit of$229.35 dollars to the existing charged off account balance. Defendant will not be prejudiced as a result of this credit. Plaintiff requests that this Court enter an Order allowing Plaintiff to file the Amended Stipulation attached hereto pursuant to Pa.R.C.P. No. 1033. WHEREFORE, Plaintiff, DISCOVER BANK, respectfully requests this Honorable Court grant Plaintiff s Motion for Leave of Court to File Amended Complaint. APOTHAKER&ASSOCIATES, P.C. Attorney for Plaintiff A Law Firm Engaged in ebt C lection B Kimbe y F. Scian, Esquire Our File No.: 275527 APOTHAKER& ASSOCIATES, P.C. By: Kimberly F. Scian, Esquire Attorney I.D. #55140 520 Fellowship Road C306 Mount Laurel,NJ 08054 (800) 672-0215 Attorneys for Plaintiff COURT OF COMMON PLEAS OF DISCOVER BANK ) CUMBERLAND COUNTY Plaintiff ) VS. ) NO.: 10-5081-CIVIL TERM ROSANN S FAUST ) Civil Action Defendant ) CERTIFICATION OF SERVICE I, Kimberly F. Scian, Esquire, attorney for Plaintiff, certify that on-- / 2-,::.,Z , I caused to be served a copy of Plaintiff's Order, Motion for Leave of Court to File Amended Complaint and Brief in Support by mail on: ROSANN S FAUST 4 ROCKLEDGE CT CARLISLE, PA 17015-9190 APOTHAKER&ASSOCIATES, P.C. Attorney for Plaintiff A Law Firm Engaged n Debt Collection BY: Ki ber7 ly F. Scian, Esquire Our file No.: 275527 Apothaker&Associates, P.C. 520 Fellowship Road C306 Mount Laurel,NJ 08054 (800) 672-0215 Attorneys for Plaintiff DISCOVER BANK ) COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, ) vs. ) DOCKET NO.: 10-5081-CIVIL TERM ROSANN S FAUST ) Civil Action Defendant. ) STIPULATION IN LIEU OF JUDGMENT The matters and things in controversy having been discussed by and between the parties, and a settlement having been agreed upon: It is on March 18, 2013, STIPULATED by and between DISCOVER BANK ("Plaintiff') and ROSANN S FAUST ("Defendant"), as follows: 1. Defendant agrees to pay the sum of $13,365.62, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. As of this date, payments totaling $9,330.00 have been applied to the aforementioned sum. 3. The sum aforesaid of$13,365.62 shall be paid by the by Defendant, ROSANN S FAUST, to the attorneys for Plaintiff in the following manner: a. $380.00 due on or before the 24th day of each month, beginning September 24, 2010 thru December 24, 2010; b. $200.00 due on or before the 24th day of each month, beginning January 24, 2011 thru April 24, 2011; c. $380.00 due on or before the 24th day of each month, beginning May 24, 2011 thru December 24, 2011; d. $200.00 due on or before the 24th day of each month, beginning January 24, 2012 thru April 24, 2012; e. $380.00 due on or before the 24th day of each month, beginning May 24, 2012 thru December 24, 2012; f. $200.00 due on or before the 24th day of each month, beginning January 24, 2013 thru April 24, 2013 1 g. $380.00 due on or before the 24th day of each month, beginning May 24, 2010 thru July 13, 2013; h. $2,225.62 due on or before August 24, 2013. All checks are to made payable to DISCOVER BANK, and sent to: Apothaker&Associates, P.C. 520 Fellowship Road C306 Mount Laurel,NJ 08054 4. As of this date, payments totaling $9,330.00 have been applied to the aforementioned sum leaving a balance due of$4,035.62. 5. In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation, then, and in that event, Plaintiff shall be entitled to obtain the entry of Judgment against Defendant ex parte, in the sum of $13,365.62, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. 6. In the event of default as aforesaid, Plaintiff shall be entitled to obtain the entry of Judgment upon ex parte application, with supporting certification, and with notice to Defendant only in the form of a copy of the application addressed to ROSANN S FAUST by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. By: Benjamin J. Cavallaro, Esquire Attorney ID# 307949 Apothaker&Associates,P.C. Attorneys for Plaintiff By: ROSANN S FAUST Defendant 2 i DISCOVER BANK BY ITS SERVICING ' AGENT DFS SERVICES LLC, Plaintiff IN THE COURT OF COMMON PLEAS V. OF THE NINTH JUDICIAL DISTRICT ROSANN S. FAUST, Defendant 2010-05081 — CIVIL TERM IN RE: MOTION FOR LEAVE OF COURT TO FILE AMENDED STIPULATION ORDER OF COURT AND NOW, this 26th day of March 2013, upon consideration of the Motion for Leave of Court to File Amended Stipulation, a Rule is issued upon Defendant to show cause why the relief requested should not be granted. PLAINTIFF shall effectuate service of this Rule upon Defendant. Proof of service must be filed prior to the court entertaining a motion to make rule absolute. RULE RETURNABLE within 20 days from the date of service by Plaintiff. BY THE COURT, Thomas A. Placey C.P.J. Distribution List: /Kimberly F. Scian, Esq. c Benjamin J. Cavallaro, Esq. --D3 W Mrm = 520 Fellowship Road C306 iM ::3. Mount Laurel, NJ 08054 rn ; Rosann S. Faust 4 Rockledge Court x'C`° Carlisle, PA 17015-9190 Y,? ii . (mod -312/X3 le1l(l 4 ur ��ROTNpNOTAR , � Our File No.: 275527 � 1013 APR t 0 AM APOTHAKER&ASSOCIATES, P.C. 11 19 BY: Kimberly F. Scian, Esquire CUMBERLAND COUNTY Attorney I.D.# 55140 PENNSYLVANIA 520 Fellowship Road C306 Mount Laurel,NJ 08054 (800) 672-0215 Attorney for Plaintiff COURT OF COMMON PLEAS DISCOVER BANK ) CUMBERLAND COUNTY Plaintiff ) vs. ) NO.: 10-5081-CIVIL TERM ROSANN S FAUST ) Defendant ) CERTIFICATION OF SERVICE S 1, Kimberly F. Scian, Esquire, attorney for Plaintiff, certify that on April;, 2013, caused to be served a copy of Plaintiff's Rule to Show Cause by regular mail to ROSANN S FAUST 4 ROCKLEDGE CT CARLISLE, PA 17015-9190 Fes, .r Ki ber y F. Scian, Esquire Attor�y for Plaintiff s U.S.POSTAL SERVICE CERTIFICATE OF MAILING MAY BE USED FOR DOMESTIC AND INTERNATIONAL MAIL,D PROVIDE FOR INSURANCE-POSTMASTER OES NOT Re ceiv v rti I-� C E! ' 'SNIP ROAD SO INT ^ REL, N.10 :5 £tOZ o 4, One Of lC W ail addressed to: -.. b a a ROSANN S FAUST 0 o 4 ROCKLEDGE CT 3 CARLISLE, PA 17015-9 �'jQj, o to PS Form 3817,January 2001 Tf Our File No.: 275527 ,iQ T1101,oLT + APOTHAKER& ASSOCIATES, P.C. l J J, BY: David J. Apothaker, Esquire PM 2 7 Attorney I.D.# 38423 C U"IIRE�j At-iD 520 Fellowship Road C306 NIVS) LV colj�l y Mount Laurel,NJ 08054 (800) 672-0215 Attorney for Plaintiff DISCOVER BANK ) COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, ) vs. ) ROSANN S FAUST ) NO. 10-5081-CIVIL TERM Defendant. ) PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER& A CIATES, P.C. Attorneys or PI intiff A Law Firm Enga ed in ebt Collection. By: David J. Apothaker, Esquire * Q 2 7 5 5 2 7 D I S M 1 -