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HomeMy WebLinkAbout11-3118Our File No.: 298200 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 2500 LANE COOK ROAD RIVERWOOD, IL 60015 Plaintiff, vs. MATHEW D SNYDER 94 ONEIDA RD CAMP HILL, PA 17011 Defendant. i t F)F1O H0N0TA R 2011 MAR 18 PM 3: G,, CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 11,3118 CAW 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 S a"k sgaoo ed a ?W e- I,*. g*asLBis Our File No.: 298200 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 2500 LANE COOK ROAD RIVERWOOD, IL 60015 Plaintiff, vs. MATHEW D SNYDER 94 ONEIDA RD CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is Discover Bank ("Plaintiff"), a Delaware State Bank and issuer of the Discover Card. 2. Defendant(s) is/are MATHEW D SNYDER, an adult individual residing at 94 ONEIDA RD CAMP HILL, PA 17011. 3. At the special instance and request of Defendant, Plaintiff, DISCOVER BANK, issued to Defendant(s), Account # ending in 4796. 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 $12,200.44. 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 $12,200.44 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney fo 1 ' ntiff A Law Firm EnRaZ i ebt Collection BY: David J. Ap*Xr, Esquire Dated: 3/14/2011 Our File No.: 298200 s VERIFICATION David J. Apothaker, Esquire, Esc. 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. 49,04 rolating to unsworn falsification to authorities. David J. Apot aker, Esquire Attorney fo laintiff DATE: 3/14/2011 s DISCOVER BANK MATHEW D SNYDER 94 ONEIDA RD CAMP HILL, PA 17011 STATEMENT OF ACCOUNT Debtor's Name: MATHEW D SNYDER Account Number: ending in 4796 Balance Due: $12,200.44 Our File No.: 298200 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff 4 O THE PR Ho.?4CT PY Jody S Smith Chief Deputy Richard W Stewart Solicitor 2011 MAR 3p PH 3: 24 CUMBERLAND COUNTY PENNSYLVANIA Discover Bank vs. Mathew D. Snyder Case Number 2011-3118 SHERIFF'S RETURN OF SERVICE 03/28/2011 06:22 PM - Shawn Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on March 28, 2011 at 1822 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Mathew D. Snyder, by making known unto himself personally, at 497 Lexington Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $53.00 March 29, 2011 A Jj 4 4 G LL, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF c („n,,. to She- 7e'. eccoli. i..,;