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Home My WebLink About11-3434Our File No.: 303819 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. ANNE K MCGINN 218 INDIAN CREEK DR MECHANICSBURG, PA 17050-2526 Defendant. it E' 'R0TNCN0TAR)'1011 APR -4 PM 2: 32 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. V1 ?I 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 3 o voA U 99 00 Pd a"d- 12?6t57y5'7 Our File No.: 303819 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. ANNE K MCGINN 218 INDIAN CREEK DR MECHANICSBURG, PA 17050-2526 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 ANNE K MCGINN, an adult individual residing at 218 INDIAN CREEK DR MECHANICSBURG, PA 17050-2526. 3. At the special instance and request of Defendant, Plaintiff, DISCOVER BANK, issued to Defendant(s), Account # ending in 4754. 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 $5,903.34. 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 $5,903.34 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASS TES, P.C. Attorney for ain A Law Firm EnaaQed/m De At Collectf?i BY: Dated: 3/28/2011 David J. Apoth ker, Esquire Our File No.: 303819 I 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. 49 rela ng to unworn falsification to authorities. David J. Apothake'r; -rsqui Attorney for Plaintiff DATE: 3/28/2011 DISCOVER BANK ANNE K MCGINN 218 INDIAN CREEK DR MECHANICSBURG, PA 17050-2526 STATEMENT OF ACCOUNT Debtor's Name: ANNE K MCGINN Account Number: ending in 4754 Balance Due: $5,903.34 Our File No.: 303819 EXHIBIT "A"