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Home My WebLink About10-5330Our File No.: 275 849 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. MARY KOLL 805 LINWOOD ST NEW CUMBERLAND, PA 17070-1443 Defendant. .2010 AVM 137M fH:oFs COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 10 -5'-j3 C-' C, V-t 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 49a.oo ?a 414? ?/# l9 3935 ? -2y cc-743 Our File No.: 275849 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothakei, 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. MARY KOLL 805 LINWOOD ST NEW CUMBERLAND, PA 17070-1443 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 MARY KOLL, an adult individual residing at 805 LINWOOD ST NEW CUMBERLAND, PA 17070-1443. 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 5197. 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 $4,200.11. 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 $4,200.11 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASS IA ES, P.C. Attorney for ain A Law Firm Engaged De Collection BY: David J. Dated: 8/5/2010 Our File No.: 275849 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. 4904a4g to unworn falsification to authorities. David J. Apoth er, Esquire Attorney for laintiff DATE: 8/5/2010 DISCOVER BANK BY ITS SERVICING AGENT DFS SERVICES, LLC MARY KOLL 805 LINWOOD ST NEW CUMBERLAND, PA 17070-1443 STATEMENT OF ACCOUNT Debtor's Name: MARY KOLL Account Number: ending in 5197 Balance Due: $4,200.11 Our File No.: 275849 EXHIBIT "A" 275849 Request for Service R. Thomas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.6390 Fx: 717-240-6397 Plaintiffs: Court Number: DISCOVER BANK BY ITS SERVICING AGENT DFS SERVICES, LLC Defendants: MARY KOLL Serve Upon: MARY KOLL Address for Service: 805 LINWOOD ST NEW CUMBERLAND, PA 17070-1443 Alternate Address for Service. Expiration Date: Type of Action: Civil Action Type of Service: ( ) Personal (X) Adult in Charge () Deputize () Certified Mail () 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 COU~E Ronny R Anderson ~ .~~ ,~~,~.~ T Sheriff ~~' Jod S Smith ~9~,~,tr mt t`ir~t~brr~~~0 y ~~ ~~~~G 31 AM 8~ 36 Chief Deputy ~ f4, ~ ~~-; ~ ~ gyn. Richard W Stewart C~h~~:.t <~.~,tJ ti~C~3~ Solicitor ~~{c~ ~ = rt.~ sMERI~F ~ p~NP~~II.VANIA Discover Bank vs. Case Number Mary Koll 2010-5330 SHERIFF'S RETURN OF SERVICE 08/18/2010 04:50 PM -William Cline, Corporal, who being duly sworn according to law, states that on August 18, 2010 at 1650 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Mary Koll, by making known unto herself personally, at 805 Linwood Street, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to her personally the said true and correct copy of the same. `~~ C._._ I LIAM CLINE, DEPUTY SHERIFF COST: $43.30 August 26, 2010 SO ANSWERS, ~~" RON R ANDERSON, SHERIFF ;ci CountySuite Sheriff, Teleosoff. Inc. Our File No.: 275849 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 Plaintiff, vs. MARY KOLL Defendant. OF T~lE PRflI'NONtITAP~Y ~a~a acj ~ ~ ~~ 2~ ~~ ,,~', CUMB~RLSY~VAHIA TY PENN COURT OF COMMON PLEAS CUMBERLAND COUNTY } NO. 10-5330 CIVIL PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASS TES, P.C. Attorneys f 1 'tiff A Law Firm En~a~ in ebt Collection By: David J. Dated: 10/7/2010 omniii~mn ,Esquire