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Home My WebLink About10-50831 Our File No.: 275468 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. RANDY L MINICH 412 ROXBURY RD NEWVILLE, PA 17241-8632 Defendant. i. P Pc; .!!j ' 3 v aor?tjja I?u(? 3 fwt a:33 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: (O - 5083 a,tv i 1 -t? rM 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 0 4ga.o o P0 AYN e,-` lq aaly P-1 &y to oa7 w Our File No.: 275468 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. RANDY L MINICH 412 ROXBURY RD NEWVILLE, PA 17241-8632 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 RANDY L MINICH, an adult individual residing at 412 ROXBURY RD NEWVILLE, PA 17241-8632. 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 9168. 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 $3,925.51. 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 $3,925.51 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & red CIATES, P.C. Attorney aintiff A Law Firm En2a Debt Collection BY: Dated: 7/28/2010 David J. Apoer, Esquire Our File No.: 275468 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 at g to unworn falsification to authorities. David J. Apothakellk Attorney for Plai DATE: 7/28/2010 DISCOVER BANK BY ITS SERVICING AGENT DFS SERVICES, LLC RANDY L MINICH 412 ROXBURY RD NEWVILLE, PA 17241-8632 STATEMENT OF ACCOUNT Debtor's Name: RANDY L MINICH Account Number: ending in 9168 Balance Due: $3,925.51 Our File No.: 275468 EXHIBIT "A" f r f Our file No.: 275468 ' 3 APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff Attorney ID# 307949 DISCOVER BANK BY ITS SERVICING AGENT DFS SERVICES, LLC Plaintiff, vs. RANDY L MINICH i COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET INO.: 10-5083 CIVIL TnRIO 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 August 20, 2010, STIPULATED by and between Plaintiff, DISCOVER BANK BY ITS SERVICING AGENT DFS SERVICES, LLC, and Defendant, RANDY L MINICH parties as follows: 1. Defendant agrees to pay the sum of $4,117.51, 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 $4,117.51 shall be paid by the by Defendant, RAi'vi)'Y L -TWIQCH, to the attorneys for Plaintiifin the following manner: C- c: =n a. $555.50 due on or before the 27th day of each month, beginni rr? jg ' ui' 27, 2010 thru January 27, 2011. . , rn y ; All checks are to made payable to DISCOVER BANK BY ITS ] SERVICING AGENT DFS SERVICES, LLC, and sent to: C: _ rn Apothaker & Associates, P.C. w 520 Fellowship Road C306 Mount Laurel, NJ 08054 3. In the event Defendant, RANDY L MINICH makes all payments as stated above, this account will marked satisfied when RANDY L MINICH pays $3,333.00. I 4. 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 $4,117.51, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. 5. 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 RANDY L MINICH by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES, P.C. Attorneys forr ?jlaintiff A Law Firah E ga?fl i Debt Collection By: Cavallaro, Esquire RAN L MIN CH Our File No.: 275468 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 2011 FEB 28 PM 3- 51 rUMBERLAND COUNTY pCNNgYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, vs. NO. 10-5083 CIVIL TERM RANDY L MINICH Defendant. PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & Attome A Law Firm En a By: David J. A SOCIATES, P.C. r Plaintiff in Debt Collection , Esquire Dated: 2/17/2011 ?IIIIIIII?IIII?