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Our File No.: 182388
APIOTHAKER & ASSOCIATES, P.C.
BY: David J. Apothaker, Esquire, Esq.
Attorney I.D.#38423
520 Fellowship Road C306
Mount Laurel, NJ 08054
(800) 672-0215
Attorneys for Plaintiff
CHASE BANK USA, N.A.
c/o Apothaker & Associates, P.C
520 Fellowship Road C306
Mount Laurel, NJ 08054
Plaintiff,
vs.
MARY A NICKEY
60 GORDON DRIVE
CARLISLE, PA 17013
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.. et- ?-7s3 PW
CIVIL ACTION COMPLAINT
FIRST COUNT
1. Plaintiff is CHASE BANK USA, N.A. c/o Apothaker & Associates, P.C., 520 Fellowship Road
C306, Mount Laurel, NJ 08054.
2. Defendant(s) is/are MARY A NICKEY, an adult individual residing at 60 GORDON DRIVE
CARLISLE, PA 17013.
3. At the special instance and request of Defendant, Plaintiff, CHASE BANK USA, N.A., issued to
Defendant(s), Account #033217480452.
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 $2,675.10. 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
$2,675.10 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law.
APOTHAKER & A CIATES, P.C.
Attorney r aintiff
A Law Firm End 9-Debt CoW6ioi
BY:
Dated: 9/23/2008
David J. ApoiAer, Esquire
Our File No.: 182388
1
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,Ad belief. The undersigned understands that the statements
therein are made subject to the penalties of 18 Pa.C.?.A. 4904 Olating to unsworn falsification to authorities.
David J. Apothaker, Esquire
Attorney for Plaintiff
DATE: 9/23/2008
I?a? lv
KOM ..
P.O. Box 3004
MILWAUKEE, W1 53201-3004
CREDITOR: Chase Bank USA, N.A.
RE: Kohl's Department Stores, Inc.
Account Number: 0332174804 52 Stmt Closing Date :10/06/2007
Statement Date: 1010612007 Stmt Due Date 1110612007
Previous Balance 2628.95 4
MARY A NICKEY Total Charges 00 . 711
Total Payments .00
485 BERLIN PLANK RD Total Credits .00
SOMERSET, PA 15501-2415 Finance Charge 46.15
New Balance : 2675.10
Min Pay Method : % Bat Minimum Due 80.00
Credit Limit : 100 Amount Past Due 848.00
Available Credit: 0.00 Total Payment Now Due 928.00
Min Finance Chg : 0.50 Finance Charge Free Payment; 2675.10
Stmt Putt Code .
Annual Pct Rate Monthly Periodic Rate Avg Daily Balance Finance Charge
21-90% 1.82% 2528.95 46.15
0.00 0.00 0.00 0.00
0.00 0.00 0.00 0.00
- K011US CREDIT ` P.O. BOY 3803 • M1LWAVKEF, w7 53201 • 1•$00-$15-4151 '
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SHERIFF'S RETURN - REGULAR
CASE NO: 2008-05783 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
CHASE BANK USA NA
VS
NICKEY MARY A
MARK CONKLIN Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
NICKEY MARY A
was served upon
the
DEFENDANT , at 0015:00 HOURS, on the 3rd day of October , 2008
at 60 GORDON DRIVE
CARLISLE, PA 17013
MARY NICKEY
DEFENDANT
by handing to
a true and attested copy of COMPLAINT & NOTICE
together with
and at the same time directing Her attention to the contents thereof.
Sheriff's Costs:
Docketing 18.00
Service 5.00
Affidavit .00
Surcharge 10.00
j0111JD? .00
33.00
Sworn and Subscibed to
before me this day
So Answers:
.H
ej; ? -e?
R. Thomas Kline
10/07/2008
APOTHAKER & ASSOCIATES
By.
Deputy S erif
0 f A. D.
t
Our File No.: 182388
APOTHAKER & ASSOCIATES, P.C.
BY: David J. Apothaker, Esquire
Attorney I.D.# 38423
520 Fellowship Road C306
Mount Laurel, NJ 08054
(800) 672-0215
Attorney for Plaintiff
CHASE BANK USA, N.A.
Plaintiff,
vs.
MARY A NICKEY
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 08-5783
PRAECIPE TO DISMISS WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Kindly dismiss this action without prejudice.
APOTHAKER & A$,90(7IATES, P.C.
A Law Firm Engalfed in/Debt Collection
By:
David J. Apothaker, Esquire
Dated: March 18, 2009
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