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Home My WebLink About14-5999 Supreme Cour-.t-of Pennsylvania Cou-1 h Pleas 4f�4 �il' i°+Pl<v f For ProtlfoJ101nrt'Use Onv: f C $ " ► D County Docket No: _ q �9610t Col." The information collected on this fornz is used solely for court administration purposes. This„forrni does not supplerrrent or replace the filing and sen ice of pleadings or other papers as required by 1mv or-nodes o,f court S Commencement of Action: E ®Complaint ❑Writ of Summons ❑Petition ❑Transfer from Another Jurisdiction ❑Declaration of Taking T Lead Plaintiff's Name: Lead Defendant's Name: DISCOVER BANK LORRAINE M KRICK i I ® 0 Are money damages requested? ® Yes ❑ Dollar Amount Requested: within arbitration limits N No (check one) ❑outside arbitration limits I A Is this a Class Action Suit? ❑ Yes ® Is this an MDJAppeal? ❑ Yes ® No No Name of Plaintiff/Appellant's Attorney: Anothaker Scian P.C. ❑ Check here if you have no attorney (are a Self-Represented [Pro Se] Litigant) I r 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. j TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL.APPEALS ! ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ® Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection:Other ❑ Board of Elections ❑ Nuisance ❑ Dept.of Transportation ❑ Premises Liability _] Statutory Appeal:Other j S ❑ Product Liability(does not ' E ❑ Employment Dispute; include mass tort) HDiscriminationSlander/LibeU ❑Defamation Other. Employment Dispute: Other ❑ Zoning Board T ❑ Other: ❑ Other: € N MASS TORT F-1 Asbestos MISCELLANEOUS 1:1 Tobacco ❑ Toxic Tort-DES REAL PROPERTY F-] CommonLaw/Statutory ❑ Toxic Tort-Implant F-1EJectment Arbitration ❑ Toxic Waste F-] EminentDomain/Condemnation ❑ Declaratory Judgment F] Other: ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations ❑ Mortgage Foreclosure:Residential Restraining Order ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto < PROFESSIONAL ❑ Partition ❑ Replevin LIABLITY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: ❑ Legal ❑ Medical ❑ Other Professional: Updated 111/2011 FILED-OFFICE Our File No.: 382904 F THE PROTHONOTARY Apothaker Scian P.C. �QI�OCT _9 ��l�� By: David J. Apothaker, Esquire Attorney I.D. #38423 CUMBERLAND COUNTY 520 Fellowship Road Suite C306 PENNSYLVANIA PO Box 5496 Mt. Laurel, NJ 08054-5496 (800) 672-0215 Attorneys for Plaintiff DISCOVER BANK ) COURT OF COMMON PLEAS CIO DB SERVICING CORPORATION, ) CUMBERLAND COUNTY 6500 NEW ALBANY ROAD NEW ALBANY, OH 43054 ) NO.: lq - 5y?? Plaintiff, ) vs. ) LORRAINE M KRICK ) 2239 CANTERBURY DR ) MECHANICSBURG, PA 17055-5772 ) Defendant. ) 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 s' 717-249-3166 �( G� Our File No.: 382904 Apothaker Scian P.C. By: David J. Apothaker, Esquire Attorney I.D. #38423 520 Fellowship Road Suite C306 PO Box 5496 Mt. Laurel, NJ 08054-5496 (800) 672-0215 Attorneys for Plaintiff DISCOVER BANK ) COURT OF COMMON PLEAS C/O DB SERVICING CORPORATION, ) CUMBERLAND COUNTY 6500 NEW ALBANY ROAD ) NEW ALBANY, OH 43054 ) NO.: Plaintiff, ) vs. ) LORRAINE M KRICK ) 2239 CANTERBURY DR ) MECHANICSBURG, PA 17055-5772 ) Defendant. ) 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 LORRAINE M KRICK ("Defendant"), an adult individual residing at 2239 CANTERBURY DR, MECHANICSBURG, PA 17055-5772. 3. At the special instance and request of Defendant, Plaintiff issued a credit account ("Account") to Defendant. 4. The Account number ends in 9010. 5. Defendant received, accepted and used the account by making purchases, balance transfers, and/or cash advances. 6. The account is in default due to Defendant's failure to make timely payments. 7. Although demand has been made, Defendant has failed to make payment of the amount due. 8. The amount due as of this date is $3,054.85. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of$3,054.85 and requests this Court award costs to the extent permitted by applicable law. ApotQian P.C. AttoPlaintiff A Law Firm En Debt Col tion BY: David J. Apoth er, Esquire Our File No.: 382904 G VERIFICATION (Name) (Title) of DB Servicing Corporation,the servicing affiliate of 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 states,that llis a duly authorized representative of plaintiff herein.Additionalk��g verifies that Discover Bank, f/k/a Greenwood Trust Company, which is an FDIC-insured Delaware state bank, lacks sufficient knowledge or information to verify this complaint:67e verifies than,-Szis authorized to make this verification. As an employee of DB Servicing Corporatione has sufficient knowledge and information to make this verification, and consequently verifies that the facts set forth in the foregoing complaint are true and correct to the best o hi r knowledge and information and that 6�e is personally familiar with the account and the relationship between Discover Bank and DB Servicing Corporation. It is further stated that Discover Bank and DB Servicing Corporation extend credit through issuance of the Discover Card. As the servicing affiliate,DB Servicing Corporation performs a variety of services for Discover Bank, including business management services in support of Discover Bank business lines, including, among other things, credit card, deposits,personal loans and student loans, customer service, collections, credit risk, collection of delinquent accounts and other support services. The collection of delinquent accounts includes the right to forward the same to the attorneys and/or collection agencies for collection and to file suit on Discover Bank's behalf. Both DB Servicing Corporation and Discover Bank are wholly owned s sidiaries of D' cover Fina *al Services.._ zo _ (Signature) Defendant's Name: LORRAINE M KRICK DB Servicing Corporation, servicing affiliate Account Number: ending in 9010 of Discover Bank Our File No.: 382904 6500 New Albany Road New Albany, OH 43054 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY i ROTHU; P�: OF THE�. OCT 21 Pti 2: CUMBERLAND VC A' ' pENNSYL Discover Bank vs. Lorraine M Krick Case Number 2014-5999 SHERIFF'S RETURN OF SERVICE 10/10/2014 06:17 PM - Deputy Jamie DiMartile, 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: Lorraine M Krick at 2239 Canterbury Drive, Upper Allen, Mechanicsburg, PA 17055. E DIMARTILE, DEPUTY SHERIFF COST: $39.30 SO ANSWERS, October 15, 2014 RONI\TY R ANDERSON, SHERIFF (cif CountySuite Sheriff, Teieosoft, enc.