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Home My WebLink About12-0989Our File No.: 332537 APOTHAKER & ASSOCIATES, P.C. BY: Kimberly F. Scian, Esquire Attorney I.D. #55140 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff MISSISSIPPI STATE UNIVERSITY 449 HARDY ROAD MISSISSIPPI STATE, MS 39762 Plaintiff, vs. GERI L PYLE 5209 DEERFIELD AVE MECHANICSBURG, PA 17050 Defendant. r !C ?O -OFF/C s /E pro T [JONO f zolz fiEB ! 5 t? A? ? C!7r1'FgAND COUNT YLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY /? NO.: got?- 9 ? 9 Chill 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 a) Qtv,? e 103.5 ? alb C? 1 sss J ?# a-I) oqy 41 • Our File No.: 332537 APOTHAKER & ASSOCIATES, P.C. BY: Kimberly F. Scian, Esquire Attorney I.D. #55140 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff COURT OF COMMON PLEAS CUMBERLAND COUNTY MISSISSIPPI STATE UNIVERSITY 449 HARDY ROAD MISSISSIPPI STATE, MS 39762 Plaintiff, vs. GERI L PYLE 5209 DEERFIELD AVE MECHANICSBURG, PA 17050 Defendant. NO.: CIVIL ACTION COMPLAINT FIRST COUNT Plaintiff is MISSISSIPPI STATE UNIVERSITY, 449 HARDY ROAD, MISSISSIPPI STATE, MS 39762. 2. Defendant(s) is/are GERI L PYLE, an adult individual residing at 5209 DEERFIELD AVE MECHANICSBURG, PA 17050. 3. At the special insistence and request of the Defendant, while the Defendant was enrolled at MISSISSIPPI STATE UNIVERSITY, the Defendant entered into oral and/or implied contracts of law, wherein the Plaintiff was to provide certain educational services to the Defendant 4. The Defendant has an outstanding balance of $2,697.00 which represents the cost of tuition as set forth in Exhibit "A". 5. Although demand has been made repeatedly, the Defendant has refused and failed to pay the balance due, as set forth above, or any portion thereof. 6. Defendant has breached his contract with Plaintiff by not paying said balance due. w. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $2,697.00 plus costs. APOTHAKER & ASSOCIATES, P.C. Attorney for Ply'ntiff A Law Firm Engaged in ebt Collection Dated: January 30, 2012 Esquire Our File No.: 332537 VERIFICATION Kimberly F. Scian 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. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating to unworn falsification to authorities. Kimbe y F. Scian, Esquire A orney for Plaintiff DATE: January 30, 2012 ACCOUNT STATEMENT DATE August 17, 2011 INSTITUTION MISS STATE UNIV DEBTOR NAME PYLE, GERI L SS# XXX-XX-0352 ACCOUNT NUMBER Client Acct# 902453330 DATE OF LAST PAYMENT 6/8/10 INTEREST RATE ORIGINAL PRINCIPAL $ 3,037.49 INTEREST TO DATE $ - TOTAL $ 3,037.49 PAYMENTS: APPLIED TO PRINCIPAL $ - APPLIED TO INTEREST $ - LESS TOTAL OF PAYMENTS $ - UNPAID PRINCIPAL AT THIS DATE $ 3,037.49 UNPAID INTEREST AT THIS DATE $ - PLUS ASSESSED COLLECTION COST TO BORROWER $ 1,012.50 LATE CHARGES $ - TOTAL DUE $ 4,049.99 STATE OF COUNTY OF I AFFIRM THAT AS OF THIS DATE THE ABOVE BALANCE IS TRUE AND CORRECT TO THE BEST OF MY KNOWLEDGE 1 1 it SIGNATROE F SCHOO OFFICIAL DATE S RN TO AND SUBSCRIBED BEFORE ME THIS 3D DAY OF .2&\ \ . ? ? i 1A .?. Cl O RY PUBLIC(SIGNATURE) NAME ______ s j qP 10140 94166 'K NpSARV Pus 'i cw"m ExP July 7,2012 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Q?tyriu of is it l i &J",444 I is Jody S Smith Chief Deputy Richard W Stewart Solicitor Mississippi State University vs. Geri L. Pyle 1011 FEB 27 AM 8: 29 CUMBBL AND COUNTY PENNSYLVANIA Case Number 2012-989 SHERIFF'S RETURN OF SERVICE 02/21/2012 03:31 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on February 21 2012 at 1531 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Geri L. Pyle, by making known unto Nick Pyle, Husband of Defendant at 5208 Deerfield Avenue, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. DENNI RY, DEPUTY SHERIFF COST: $38.00 February 23, 2012 SO ANSWERS, RON R ANDERSON, SHERIFF icl Couni, Sutte Sher?ft. 7r?v6oS1 h?,; C' I s ,a Our File No.: 332537 : APOTHAKER & ASSOCIATES, P.C. BY: Kimberly F. Scian, Esquire ' Attornev I.D.# 55140 NO 520 Fellowship Road C306 Mount I..,aurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff -. MISSISSIPPI STATE UNIVERSITY COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, vs. GERI L PYLE NO. 2012-989 CIVIL Defendant. PRAECIPE TO DISMISS WITH PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action with prejudice. APOTHAKER & ASSOCIATES. P.C. Attorneys for Plaintiff A Law Firm Engaged in Debt Collection By: ?mb rly F. Scian, Esquire Dated: March 6, 2012 11111111ilAM???1111MMIAIm?11111