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Home My WebLink About08-6338{slur File No.: 157788 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 FIA CARD SERVICES A/K/A BANK OF AMERICA c/o Apothaker & Associates, P.C 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. PATRICIA A RODGERS 42 STEPHEN RD APT 4F CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: d$ - (03,3$ clvt`l Iet M+ 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 .. Pur File No.: 157788 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 FIA CARD SERVICES A/K/A BANK OF AMERICA c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. PATRICIA A RODGERS 42 STEPHEN RD APT 4F CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0P- 633g 1 J T41`, CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is FIA CARD SERVICES A/K/A BANK OF AMERICA c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are PATRICIA A RODGERS, an adult individual residing at 42 STEPHEN RD APT 4F CAMP HILL, PA 17011. 3. At the special instance and request of Defendant, Plaintiff, FIA CARD SERVICES A/K/A BANK OF AMERICA, issued to Defendant(s), Account #4888934999195364. 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 $3,456.61. 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 $3,456.61 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & AS C TES, P.C. Attorney f Pl ' tiff A Law Firm Enjz Y d in ebt Collectioi BY: Dated: 10/21/2008 David J. Apothem, Esquire Our File No.: 157788 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 therein are made subject to the penalties of 18 Pa.C.S.A. The undersigned understands that the statements David J. ApothaI sq Attorney for Plaintiff to unworn falsification to authorities. DATE: 10/21/2008 L y I t FIA CARD SERVICES A/K/A BANK OF AMERICA PATRICIA A RODGERS 42 STEPHEN RD APT 4F CAMP HILL, PA 17011 STATEMENT OF ACCOUNT Debtor's Name: PATRICIA A RODGERS Account Number: 4888934999195364 Balance Due: $3,456.61 Our File No.: 157788 EXHIBIT "A" m y ell 73 .. W CIA SHERIFF'S RETURN - REGULAR CASE NO: 2008-06338 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND FIA CARD SERVICES ET AL VS RODGERS PATRICIA A BRIAN BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE the RODGERS PATRICIA A was served upon DEFENDANT at 0020:36 HOURS, on the 5th day of November , 2008 at 42 STEPHEN RD APT 4F CAMP HILL, PA 17011 by handing to PATRICIA RODGERS 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 18.00 Service 15.00 Affidavit .00 Surcharge 10.00 r/r?1n? .00 43.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 11/06/2008 APOTHAKER & ASSOC TES By: //? Deputy Sheriff of A. D. Our File No.: 157788 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 FIA CARD SERVICES A/K/A BANK OF AMERICA Plaintiff, vs. PATRICIA A RODGERS Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-6338 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys for tiff A Law Firm Enga m ebt Collection By: David J. Aj otter, Esquire Dated: 12/31/2008 r.s O -ri (747 r G7 ? _ ?