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Home My WebLink About10-7533 Cur File No.: 295659 ' APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D. #38423 520 Fellowship Road C306 Mount Laurel, NJ 0$054 (800) 672-0215 Attorneys for Plaintiff DISCOVER BANK 6500 NEW ALBANY ROAD NEW ALBANY, OH 43054 Plaintiff, vs. ANDREW C SPEARS 120 PINE CREEK DR CARLISLE, PA 17013-9680 Defendant. F1LE0-QFFlCE OF Thy P~~iTroONOTARY 20l~ G~!; -5 P~1 2~ ~~~ rl1~v~~L!~,rti0 COUNTY P~~s',t~~ ~'LY",~~lA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. lO - ~' Sa3 l 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 aze 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 cs ~q~.oo ~~.. ~4 Cl~ 9~f31~ ~.,6- asa,asY Our File No.: 295659 ' APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney LD. #38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff DISCOVER BANK 6500 NEW ALBANY ROAD NEW ALBANY, OH 43054 Plaintiff, vs. ANDREW C SPEARS 120 PINE CREEK DR CARLISLE, PA 17013-9680 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. ~Q ~~ 33 c,v I ~~r~ CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is DISCOVER BANK, 6500 NEW ALBANY ROAD, NEW ALBANY, OH 43054. 2. Defendant(s) is/are ANDREW C SPEARS, an adult individual residing at 120 PINE CREEK DR CARLISLE, PA 17013-9680. 3. At the special instance and request of Defendant, Plaintiff, DISCOVER BANK, issued to Defendant(s), Account # ending in 5857. 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 $10,226.34. A true and correct copy of the total due and owing is attached hereto, made a part hereof and mazked 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 $10,226.34 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney for 'tiff A Law Firm En~a~ m eht C:n1lPntint BY: David J. Ap~tl6a~cer, Esquire Dated: 11 /29/2010 Our File No.: 295659 VERIFICATION David J. Anothaker Esquireuire Esa 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, belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S relating to unsworn falsification to authorities. David J. A~ethaker, Esquire Attorney for Plaintiff DATE: 11/29/2010 DISCOVER BANK ANDREW C SPEARS 120 PINE CREEK DR CARLISLE, PA 17013-9680 STATEMENT OF ACCOUNT Debtor's Name: ANDREW C SPEARS Account Number: ending in 5857 Balance Due: $10,226.34 Our File No.: 295659 EXHIBIT "A" 295659 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 Plaintiff/s: Court Number: DISCOVER BANK Expiration Date: Type of Action: Civil Action Defendants: ANDREW C SPEARS Serve Upon: ANDREW C SPEARS Address for Service: 120 PINE CREEK DR CARLISLE, PA 17013-9680 Alternate Address for Service: 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 Tele hone: 215-634-8920 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FILED-OFFICE Sheriff Wit= THE PROTHONQTA"' ' ? 1`' Y Jody S Smith 7010 DEC 20 PH 2: Chief Deputy Richard W Stewart PUMB RL Y @ CI?ut ! r Solicitor LVAHIA Discover Bank Case Number vs. 2010-7533 Andrew C. Spears SHERIFF'S RETURN OF SERVICE 12/08/2010 08:44 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on December 8 2010 at 2044 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Andrew C. Spears, by making known unto himself personally, at 120 Pine Creek Drive, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. r DENNIS RY, DEPU SHERIFF COST: $33.40 December 13, 2010 SO ANSWERS,] RON W R ANDERSON, SHERIFF Our File No.: 295659 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 Plaintiff, vs. ANDREW C SPEARS Defendant. FILED-OFFICE OF THE pROTHONOTAR'Y 2011, 3; 49 T`( " CUtA'> COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-7533-CIVILTERM PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & *_?OCIATES, P.C. A Law Firm Erhaaed in Debt By: David J. Nthaker, Esquire Dated: 1/6/2011