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Home My WebLink About11-8522Our File INo.: 328621 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 c/o DB SERVICING CORPORATION 6500 NEW ALBANY RD NEW ALBANY OHIO 43054 Plaintiff, VS. GAIL F LONSBERRY 111 MAY DR APT 2 CAMP HILL, PA 17011-5023 Defendant. f,?r TI?ELPROTHO OTARY 2011 NOV 14 PM 1: 51 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: // - 8S- ,. C [-zL Fe,, 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 9? .64) )CL-041? ?lC? ?/d34?b ,? a67-2,40 Our File No.: 328621 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. c/o DB SERVICING CORPORATION 6500 NEW ALBANY RD NEW ALBANY OHIO 43054 Plaintiff, Vs. GAIL F LONSBERRY 111 MAY DR APT 2 CAMP HILL, PA 17011-5023 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 GAIL F LONSBERRY, an adult individual residing at 111 MAY DR APT 2 CAMP HILL, PA 17011-5023. 3. At the special instance and request of Defendant, Plaintiff, DISCOVER BANK, issued to Defendant(s), Account # ending in 9059. 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 $11,319.76. 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 $11,319.76 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER SSOCIATES, P.C. Atto ey r Plaintiff A Law Firm E Jza d in Debt Collection BY: David J. A4t*er, Esquire Dated: 10/24/2011 Our File No.: 328621 VERIFICATION David J. Apothaker, Esquire, 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 made subject to the penalties of 18 Pa.C.S.A. 4904 undersigned understands that the statements therein are to unsworn falsification to authorities. David J. Af Rhaker, Esquire Attorney for Plaintiff DATE: 10/24/2011 • New Balance Minimum Payment Due Account Number ending in 9059 DISCOVER $0.00 $2,379.00 Enter Amount Enclosed Below Payment Due Date $ !) Apra 28, 2011 31 SDSN6A010018441 GAIL LONSBERRY 111 MAY DR APT 2 CAMP HILL PA 17011-5023 Go paperless and make your account information more secure with password- protected statements only you can access. Learn more at discover.comlpaperless. PO BOX 6103 1111111111111111111111131111 CAROL STREAM IL 60197-6103 Address, e-mail or telephone change? Irllu??uu+rlllrlnlurlrllnnr)Illunr)Irllnur)?ulu)I Go to www.Discover.com or print change in space above. -1 1 G)pening care: IM FM lar AV 1 r - %4V.l114y v.no. nw, Discover More Card Account Summary Account number ending in 9059 Previous Balance $11,319.76 Payments And Credits 11,319.76 Purchases + 0.00 Balance Transfers + 0.00 Cash Advances + 0.00 Fees Charged + 0.00 interest Charged + 0.00 New Balance 0.00 See Interest Charge Calculation section Following transactions for detailed APR information Credit line $10,000.00 Credit Line Available $0.00 Cash Advance Credit Line $7,500.01C Cash Advance Credit Line Available $O.OC 31, LU I I W5° I Payment Information New Balance $0.00 Minimum Payment Due $2,379.00 Payment Due Date April 28, 2011 late Payment Warning: If we do not receive your minimum payment by the date listed above, you may have to pay a late Fee of up to $35.00 and your purchase and balance transfer APRs for new transactions may be increased up to the Penalty APR of 29.99% variable. Manage Your Account Online at www.Diswver.com • securely access statements and free online tools, pay bills online and track and view all transactions simply and easily • Make your money worth moresm-find easy ways to earn and redeem cash rewards • NEW1 Access your account securely through your mobile phone 3 Easv ways to Contact Us Cash BOttUSe 1. Access your account securely of vwrw.Discover.com Anniversary Month 2. Call 1-800-DISCOVER (1-800.347-2683) November Please have your Discover®card available. $ 0.00 3. Write to us at Discover PO Box 30943, Opening Cashb«k Bonus Balance Salt Lake City, UT 841 50 (Not a payment address) New Cashback Bonus This Period + 0.00 For payments ease send to address on remittance or Cashback Bonus Balance $ 0.00 Discover, PO Box 6103, Carol Stream, IL 60197-6103 To learn more, log in ar www.Dimwr.com For TM (Telecommunications Device for the Deal) assistance, please call 1-800347-7449. Transactions Trans. Past Date Date Payments and Credits Mar 31 Mar 31 INTERNAL CHARGE-OFF $ .11,319.76 Foes TOTAL FEES FOR THIS PERIOD $ 0.00 ksurest charged TOTAL INTEREST FOR T14S PERIOD $ 0.00 2011 Totals Year-to-Date TOTAL FEES CHARGED IN 2011 $ 70.00 TOTAL INTEREST CHARGED IN 2011 559.33 NOTICE: SEE REVERSE SIDE FOR IMPORTANT INFORMATION D1SCOVER v Paperless statements mean less clutter, more Easily access up to 24 months of downloadable, password protected statement: • See your statement as soon as it's available rather than wait for it to arrive • Get helpful payment reminders through e-mail or text messages on your mo • Print a paper copy of your statement anytime. • Sign up today at Discovercom/paperless 02010 Discover Bonk, Member FDIC i 0 I I o Q C? CO I p I N X N 416 Our File No.: 328621 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 Vs. Plaintiff, GAIL F LONSBERRY Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 2011-8522-CIVIL PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER A Law Firm By: David J. Dated: 1/4/2012 '?III??INII??I?? kSSOCIATES, P.C. for Plaintiff -d in Debt Collection , Esquire c Q ?' -23 ;z -r D ? CQ ?? F3 Z C N O