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Home My WebLink About10-6441SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith ~atittity aC ~ntnb~~,~j~ ~~~.~~"~~~~~~ F ~'~~ pP~`I~NQOTAEdY Chief Deputy ~ , ~= ~~ Richard W Stewart , so-icitor ~fF'~E _"~ „'~ `"`"~~~ ~"?JNlB~RLAi~D I~~UN ~Y' `~ F~P~P~SYL~/~~~~1 Discover Bank vs. Case Number Danelle Watson 2010-6441 SHERIFF'S RETURN OF SERVICE 10/14/2010 07:33 PM -Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on October 14, 2010 at 1933 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Danelle Watson, by making known unto herself personally, at 1296 Asper Drive, Boiling Springs, Cumberland County, Pennsylvania 17007 its contents and at the same time handing to her personally the said true and correct copy of the same. WN ALL, D TY SHERIFF COST: $33.40 October 15, 2010 SO ANSWERS, ... RON R ANDERSON, SHERIFF !cj CountySuite Sher;$ T'eleosoft. In::. DISCOVER BANK BY ITS SERVICING AGENT DFS SERVICES LLC 6500 NEW ALBANY ROAD NEW ALBANY, OH 43054 Plaintiff, vs. DANELLE WATSON 1296 APSER DRIVE BOILING SPRINGS PA 17007-9614 Defendant. COURT OF COMMON PLEASE CUMBERLAND COUNT ~~ No.: 10-6441 AFFIRMATIVE DEFENSES ,~~ ~~ ~~ ~--~ ,~ ~~ ~~ ~~ ~~ ca ca c~ --~ rv cc~ x~ ~~ (~ l„Q ~-n -~~ ~, --, ~~ ~~ Now comes Defendant, Pro Se, who denies the following paragraphs of Plaintiff's Complaint: 1. Defendant denies the allegations contained in ALL Paragraphs of the Complaint as Defendant is without information or knowledge sufficient to form an opinion as to the truth and accuracy of alleged assignments and entitlements. 2. Defendant implicitly denies the allegations contained in Paragraph 2 as there is not, nor has there ever been any agreement, written, oral or implied with the Plaintiff and Defendant. 3. Defendant lacks knowledge about the truth and therefore denies allegations contained in Paragraph 3, Plaintiff has failed to provide Defendant with any kind of account numbers or documentation for alleged debt. WHEREFORE, Defendant prays that the court take nothing of Plaintiff`s Complaint by virtue and dismisses the complaint. Pro Se, Danelle Watson Defendant elle-Lynne: atson 1296 Asper Drive Boiling Springs PA 17007 OCTOBER 25, 2010 Filed in Court of Pleas by: Apothaker & Associates, P.C. David J. Apothaker, Esquire Attorney I.D. #38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff Our File No.: 287275 DISCOVER BANK BY ITS SERVICING ) AGENT DFS SERVICES LLC ) Plaintiff ) vs. ) DANELLE WATSON ) Defendant ) Esq., and PRAECIPE FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: C = rn - - :Z= - -um r <> ;?O C> z .cv - = -n 3c 0 = -n F o 4 _< O ' Kimberly F. Scian, Esquire, counsel for the Plaintiff in the above action, respectfully represents that: 1. The above-captioned action is at issue 2. The claim of Plaintiff in the action is $7178.39. The following attorneys are interested in the case as counsel or are otherwise disqualified to sit as arbitrators: For Defendant For Plaintiff Kimberly F. Scian, Esquire 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully ed, C ___` : I June 22, 2011 Ki b? ly F. Scian, Esquire jr_! r ORDER OF COURT AND NOW, and as prayed for. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: 10-6441 Civil Action Esq., Esq., are appointed arbitrators in the above captioned action By the Court, 20 , in consideration of the foregoing petition, Our File No.: 287275 DISCOVER BANK BY ITS SERVICING ) AGENT DFS SERVICES LLC ) Plaintiff ) vs. ) DANELLE WATSON ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: 10-6441 Civil Action PRAECIPE FOR APPOINTMENT OF ARBITRATORS TO THE HONORABLE, THE JUDGES OF SAID COURT: rncv c.. -? - ?yr- am ,.t cC3 - o-n >C-) v = Z c`s p?Z '? ter„ ..{ N p Kimberly F. Scian, Esquire, counsel for the Plaintiff in the above action, respectfully represents that: 1. The above-captioned action is at issue 2. The claim of Plaintiff in the action is $7178.39. The following attorneys are interested in the case as counsel or are otherwise disqualified to sit as arbitrators: For Defendant For Plaintiff Kimberly F. Scian, Esquire 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respectfully, ed, June 22, 2011 C;;Ki b?rly F. Scian, Esquire Tx.,w ?? I ORDER OF COURT 121+a0 airs AND NOW, 20!1 , in consideration of the foregoing petition, Esq., and 6 GY),teLl ll LG,Esq., and Esq., are appointed arbitrators in the above captioned action as prayed r. n ONdlN33d ewn? z) :8 kv e By the Court, I Inr iioz d V`1 ONONI08d 3NI 11 4je, 301.1.40-03113 ?>/ - C_op; esa.led -7/)a/11 RjZ t V, Our file No.: 287275 Apothaker & Associates, P.C. 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. DANELLE WATSON Defendant. fired' °?te c ? .A COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 10-6441 Civil Action 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 July 14, 2011, STIPULATED by and between DISCOVER BANK BY ITS SERVICING AGENT DFS SERVICES LLC ("Plaintiff') and DANELLE WATSON ("Defendant"), as follows: 1. Plaintiff filed suit in the above captioned matter seeking damages in the amount of $7,178.39, plus court costs in the amount of $149.40, for a total of $7,327.79. 2. Defendant agrees to pay to Plaintiff the sum of $7,178.39, plus court costs in the amount of $149.40. for a total of $7,327.79; which sum Plaintiff agrees to accept in full settlement of its claim herein. 3. As of this date, payments totaling $0.00 have been applied to the aforementioned sum. 4. Defendant shall remit payment(s) in the following manner: a. $150.00 to be paid on or before July 31, 2011; b. $305.00 to be paid on or before the 20th day of each month, beginning August 20, 2011 until paid in full. 5. All checks shall be made payable to "DISCOVER BANK BY ITS SERVICING AGENT DFS SERVICES LLC", and sent to the office of Plaintiff's attorney, Apothaker & Associates, P.C., located at the following address: 1 Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation and the default is not cured within ten (10) days, then Plaintiff shall be entitled to obtain the entry of Judgment against Defendant in the suit amount, plus court costs, as specified in paragraph one (1) of this stipulation less any sums paid pursuant to this Stipulation, upon ex parte application, with supporting certification, and with notice to Defendant in the form of a copy of the application addressed to Defendant by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. By: Hamm J. C vallaro, Esquire Atto 1l)# 307949 er & Associates, P.C. Attorneys for Plaintiff 2 DISCOVER BANK BY ITS CUMTHE COURT BERI,ANDOOUNTIY, PENNSYLVANIA SERVICING AGENT DFS SERVICES, LLC, Plaintiff CIVIL ACTION - LAW NO. 10-6441 CIVIL vs. ° r.. DANELLE WATSON, s Defendant c3 ORDER AND NOW, this Z day of September, 2011, the appointment of a B00xi ot:' Arbitrators in the above-captioned case is VACATED. Grace D'Alo, Esquire, Chairman, shall be paid the sum of $50.00. k/Grace D'Alo, Esquire '.2 .30a?t `? Court Administrator 5 30 &rectso,, Rd . (arl,sfe, PA 1-2013 :rlm eor y ma. lei 61 / / -7/ t'171 BY THE COURT, Kevin . Hess, P. J. ielel Our File No.: 287275 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. DANELLE WATSON Defendant. L r? `' 16 CC; 31 P4, 2: a I PENN'SYL COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-6441 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & AS O IATES, P.C. Attorneys fo PI 'ntiff A Law Firm Engage in ebt Collection By: David J. ApothakK?Esauire Dated: 10/26/2011 ?? II?Ib?V8 7 2 7 5 D?,WlNl1