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HomeMy WebLinkAbout14-2998 Supreme Court of Pennsylvania <<'olirt of Common Pleas I Civil Covei- Sheet Forprolhonown. Use oniv: CUMBERLAND Docket No.- .'J 7 T;,,e P;tbFWh7NMco� TeO 0�1 R,17 5 lec J077?? is liseci soie), !,b?-co"Irr adiniPis- trar"'a;? vfflposes. TTiisfi?.­m does 1(7C C. ie,:t7 (w, or -equc�7-ed bi, `nr oi-rules of ,as i I Coal" S Commencement of Action: E E Complaint F1 Writ of Summons F-1 Petition C El Transfer from Another Jurisdiction E]Declaration of Taking Lead Plaintiffs Name: Lead Defendant's Name: T DISCOVER BANK BETH L HEISERMAN I Are money damages requested? EE Yes M No Dollar Amount Requested: Z within arbitration limits 0 (check one) E]outside arbitration limits N Is this a Class Action Suit? El Yes E No Is this an MDJAppeal? El Yes E No A Name of Plaintiff/Appellant's Attorney: Apothaker Scian P.C. El Check here if you have no attorney (are a Self-Represented. [Pro Se] Litigant) Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE. If you are making more than one type of claim, check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS El Intentional El Buyer Plaintiff Administrative Agencies M Malicious Prosecution E Debt Collection: Credit Card El Board of Assessment F-1 Motor Vehicle El Debt Collection:Other El Board of Elections 0 Nuisance El Dept. of Transportation ❑Premises Liability El Statutory Appeal:Other ❑ Product Liability(does not El Employment Dispute: S include mass tort) Discrimination E E] Slander/Libel/Defamation El Employment Dispute: Other C El Other: F] Zoning Board T El Other: I I E] Other: o MASS TORT M Asbestos N 0 Tobacco C3 Toxic Tort-DES REAL PROPERTY MISCELLANEOUS E] Toxic Tort-Implant El Ejectment E] Common Law/Statutory Arbitration El Toxic Waste 0 Eminent Domain/Condemnation El Declaratory Judgment B D Other: El Ground Rent El Mandamus El Landlord/Tenant Dispute 0 Non-Domestic Relations ❑ Mortgage Foreclosure: Residential Restraining Order El Mortgage Foreclosure: Commercial 0 Quo Warranto PROFESSIONAL El Partition El Replevin LIABLITY El Quiet Title El Other: 0 Dental El Other: E3 Legal F1 Medical 0 Other Professional: Updated 11112011 F!L ED-0FI"l1r .,E Our File No.: 351712 OF T'HL PROTHONOTARY APOTHAKER SCIAN P.C. BY: David J. Apothaker, Esquire 7914 HAY 19 PV11 3' 20 Attorney I.D.# 38423 CUMBERLAND COUNT`' 520 Fellowship Road C306 PENNSYLVANIA Mount Laurel,NJ 08054 (800) 672-0215 Attorneys for Plaintiff DISCOVER BANK ) COURT OF COMMON PLEAS C/O DB SERVICING CORPORATION, 6500 ) CUMBERLAND COUNTY NEW ALBANY ROAD ) NEW ALBANY, OH 43054 ) NO.: Plaintiff, ) vs. ) BETH L HEISERMAN ) 220 LOUIS LN ) ENOLA, PA 17025 ) Defendant. ) r ) 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. 3 7. Although demand has been made, Defendant has failed to make payment of the amount due. S. The amount due as of this date is $1,309.68. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $1,309.68 and requests this Court award costs to the extent permitted by applicable law. APOTHAKERSCI C. Attorney for P inti A Law Firm Engaged i Deb Collection BY: David J. Apothak , Esquire Our File No.: 351712 VERIFICATION �.,ant, Co��i 11 L��-�ga.�riv;� Su.h�©►--�- S�-e..c ia�►slt (Name) (Title) of DB Servicing Corporation,the servicing affiliate for Discover Bank, does hereby verify, under penalty of perjury and subject to the penalties of 18 Pa. C.S. § 4904 relating to unsworn falsifications to authorities and states,that he/she is a duly authorized representative of plaintiff herein and authorized to make this verification, and that the facts set forth in the foregoing Complaint are true and accurate to the best of his/her knowledge and information and that he/she is familiar with the manner and method by which plaintiff maintains its normal business books and records, including computer records of defaulted accounts. S/he is also familiar with the relationship between Discover Bank and DB Servicing Corporation. That Discover Bank, f/k/a Greenwood Trust Company, is an FDIC insured Delaware State bank, and its servicing affiliate, DB Servicing Corporation performs a variety of services for Discover Bank including, among other things, business management services, customer service, and collection of delinquent accounts. The collection of delinquent accounts includes the right to forward the same to the attorneys to file suit on Discover Bank's behalf.Both DB Servicing Corporation and Discover Bank are wholly owned subsidiaries of Discover Financial Services. NWVJ S•gnature) Defendant's Name: BETH L HEISERMAN DB Servicing Corporation servicing Account Number: ending in 9823 affiliate for Discover Bank Our File No.: 351712 PO Box 3025 New Albany, OH 43054 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY ii p -,O T toO O'- tAti '. }di JUN -14 Ph 3: 15 rU PENNSYfL� A! { O FICE OF TH.E SHERIFF Discover Bank vs. Beth L Heiserman Case Number 2014-2998 SHERIFF'S RETURN OF SERVICE 05/21/2014 01:53 PM - Ronny R Anderson, Sheriff, being duly sworn according to law, states he made diligent search and inquiry for the within named Defendant to wit: Beth L Heiserman, but was unable to locate the Defendant in his bailiwick. The Sheriff therefore returns the within requested Complaint & Notice as "Not Found" at 220 Louis Lane, East Pennsboro, Enola, PA 17025. Defendant no longer resides at this address per current resident, Bharat Vachhan. 05/22/2201 02:51 PM - Deputy Dawn Kell, being duly sworn according to law, served the requested Complaint & Notice by "personally" handing a true copy to a person representing themselves to be the Defendant, to wit: Beth L Heiserman at 125 S. 27th Street, Camp Hill Borough, Camp Hill, PA 17011. DAWN KELL, DEPUTY SHERIFF COST: $61.90 SO ANSWERS, May 28, 2014 RONIV R ANDERSON, SHERIFF (c) CountySui,e Sheriff Teleosoft, Inc. Our File No.: 351712 Apothaker Scian P.C. By: Kimberly F. Scian, Esquire Attorney I.D. #55140 520 Fellowship Road Suite C306, PO Box 5496 Mt. Laurel, NJ 08054-5496 (800) 672-0215 Attorneys for Plaintiff DISCOVER BANK Plaintiff, vs. BETH L HEISERMAN Defendant. !7 E rr. 2014 4UG 96 CUNBERLAND COUNTY PENNSYLVANIA ) COURT OF COMMON PLEAS CUMBERLAND COUNTY ) ) ) ) NO. 2014-02998 ) ) ) ) PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. Apothaker Scian P.C. Attorneys for Plaintiff A Law Firm Engaged in Debt Collection By: Kimb - 4y F. Scian, Esquire 1111111111 1111 II i111111