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Home My WebLink About08-5990Our File No.: 185326 APOTHAKER & 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 AMERICAN EXPRESS TRAVEL RELATED SERVICES c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. LINDA HILL 431 S COLLEGE ST APT 201 CARLISLE, PA 17013 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: SM el,, Z L Eg--n 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 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 Our File No.: 185326 APOTHAKER & 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 AMERICAN EXPRESS TRAVEL RELATED SERVICES c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. LINDA HILL 431 S COLLEGE ST APT 201 CARLISLE, PA 17013 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: GAF- 5g9o 7' CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is AMERICAN EXPRESS TRAVEL RELATED SERVICES c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are LINDA HILL, an adult individual residing at 431 S COLLEGE ST APT 201 CARLISLE, PA 17013. 3. At the special instance and request of Defendant, Plaintiff, AMERICAN EXPRESS TRAVEL RELATED SERVICES, issued to Defendant(s), Account #3713-810541-71009. 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 $55,694.93. 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 $55,694.93 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & SSOCIATES, P.C. A Law Firm Eng,-(ge? inOebt Collection BY: David J. Apothaker, Esquire Dated: 9/25/2008 Our File No.: 185326 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, and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 relating to unworn falsification to authorities. David J. Apothaker, Esquire Attorney for Plaintiff DATE: 9/25/2008 AMERICAN EXPRESS TRAVEL RELATED SERVICES LINDA HILL 431 S COLLEGE ST APT 201 CARLISLE, PA 17013 STATEMENT OF ACCOUNT Debtor's Name: LINDA HILL Account Number: 3713-810541-71009 Balance Due: $55,694.93 Our File No.: 185326 EXHIBIT "A" W cs 4 w? v c- `; k: r_ 7 r' .C CD CrN C-0 0"0.7 r C? _?lY) --C SHERIFF'S RETURN - REGULAR CASE NO: 2008-05990 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND AMERICAN EXPRESS TRAVEL RELATE VS HILL LINDA ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HILL LINDA the DEFENDANT at 0013:45 HOURS, on the 8th day of October , 2008 at 431 S COLLEGE ST APT 201 CARLISLE, PA 17013 by handing to LINDA HILL DEFENDANT 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 Service Affidavit Surcharge klolor So Answers: 18.00 5.00 ? ? . .00 10.00 R Thomas Klin 00 3 10/09/2008 APOTHAKER & ASSOCIATES Sworn and Subscibed to before me this of By day Deputy Sheriff A.D. Our File No.: 185326 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 AMERICAN EXPRESS TRAVEL ) RELATED SERVICES ) Plaintiff, ) vs. ) LINDA HILL ) Defendant. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-5990 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASS IATES, P.C. Attorneys fo intiff A Law Firm Engag i ebt Collection By: David J. Apo\hr, Esquire Dated: February 19, 2009 5 1 ': 1