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Home My WebLink About08-7550W Our File No.: 194818 APOiHAKER & 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 CENTURION BANK c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. VIOLA LIMRIC 317 THIRD ST SUMMERDALE, PA 17093 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY TC?Xw- NO.: DS-7550 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.: 194818 ' 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 CENTURION BANK c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. VIOLA LIMRIC 317 THIRD ST SUMMERDALE, PA 17093 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0,F- 7-<A Lyw?l -Tu^- CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is AMERICAN EXPRESS CENTURION BANK c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are VIOLA LIMRIC, an adult individual residing at 317 THIRD ST SUMMERDALE, PA 17093. 3. At the special instance and request of Defendant, Plaintiff, AMERICAN EXPRESS CENTURION BANK, issued to Defendant(s), Account #3713-210949-51002. 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 $11,269.80. 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 $11,269.80 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & A O IATES, P.C. Attorney r P 'tiff A Law Firm Eng ed ' Debt C ectioi BY: David J. A er, Esquire Dated: 12/22/2008 Our File No.: 194818 VERIFICATION David J. Avothaker 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 bel' The undersigned understands that the statements lpf) therein are made subject to the penalties of 18 Pa.C.S.A. 4 04 r lating to unsworn falsification to authorities. David J. Apothak'?r, Esquire Attorney for Plaintiff DATE: 12/22/2008 VIOLA LIMRIC 317 THIRD ST SUMMERDALE, PA 17093 STATEMENT OF ACCOUNT Debtor's Name: Account Number: Balance Due: Our File No.: 194818 AMERICAN EXPRESS CENTURION BANK VIOLA LIMRIC 3713-210949-51002 $11,269.80 EXHIBIT "A" ;f j r rv°F r '? fl C---) T? r= ?010 ' rQ -.(?? SHERIFF'S RETURN - REGULAR CASE NO: 2008-07550 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND AMAERICAN EXPRESS CENTURION VS LIMRIC VIOLA VALERIE WEARY , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LIMRIC VIOLA the DEFENDANT at 1144:00 HOURS, on the 6th day of January , 2009 at 317 THIRD STREET SUMMERDALE, PA 17093 by handing to VIOLA LIMRIC 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 Sworn and Subscibed to before me this of So Answers: 18.00 14.40 .00 10.00 R. Thomas Kline .00 42.40 01/07/2009 APOTHAKER & ASSOCIATES By. Vd, day Deputy Sheriff A. D. ?. ,J c-n rro. Our File No.: 1948 11 . APOTHAKER & ASSOCIATES, P.C. Attorney for Plaintiff BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 AMERICAN EXPRESS CENTURION BANK ) COURT OF COMMON PLEAS OF Plaintiff, ) CUMBERLAND COUNTY VS. ) NO.: 08-7550 VIOLA LIMRIC ) Defendant. ) Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, VIOLA LIMRIC, in the default of an Answer, in the amount of $11,390.70 computed as follows: Amount claimed in complaint: $ 11,269.80 Less: Amount Paid: ( 0.00) Plus: Interest from December 22, 2008 to August 12, 2009 at the legal 0.00 interest rate of 0.00% per annum Attorney fees 0.00 TOTAL $ 11,390.70 I hereby certify that the appropriate Notices of Default, as attached have been mailed in accordance with Pa.R.Civ.P. 237.1 on the dates indicated on the Notices. I certify Defendant, VIOLA LIMRIC, last known address X? 17 THIRD ST SUMMERDALE, PA 17093. APOTHAKER & ASS TES, P.C. Attorneys for 1 intiff A Law Firm Enaaaed ebt Fe6fiectioi By: David J. Dated: August 12, 2009 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: VIOLA LIMRIC 317 THIRD ST SUMMERDALE, PA 17093 AMERICAN EXPRESS CENTURION BANK Plaintiff, vs. VIOLA LIMRIC Defendant. NOTICE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-7550 Civil Action Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgm t has been entered against you in the above proceeding as indicated below. XX JUDGMENT BY DEFAULT JUDGMENT IN REPLEVIN JUDGMENT BY CONFESSION JUDGMENT FOR POSSESSION JUDGMENT ON AWARD OF ARBITRATORS JUDGMENT ON VERDICT JUDGMENT ON COURT FINDINGS JUDGMENT ON WRIT OF REVIVAL IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker, Esq. at this telephone number: 215-634-8920 Our File No.: 1948..8 . APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff AMERICAN EXPRESS CENTURION BANK Plaintiff, vs. VIOLA LIMRIC Defendant. Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-7550 . SS. David J. Apothaker, being duly sworn according to law, deposes and says that I am the attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 317 THIRD ST SUMMERDALE, PA 17093. We inquired with the web site of the Defense Boulevard, Suite 400, Arlington, VA 22209-2593, if the Mary M. Snavely-Dixon, Director of the De indicated that the Defendant(s) is/are not in the mili David J. Apothaker Attorney for Plaintiff r Data Center, located at 1600 Wilson s) is/are in any branch of the military. Center has sent back our inquiry The above signed understands that the statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. AP'OTHAKER&AsSOCIATES, P.C. Department of Ddmse Manpower Data Gamer Military Status Refit Pursuant to the Senv ce members Civil Re UdAct -<Last lFirs e ' B egis Date Igse Adive Duty BMw ATTORNEY'S AT LAW AUG-12-2009 08:54:43 ' UNIRIC I VIOLA Based on the vion atim you have harnishe d, the DINOC does not possess my information indicating that the individual is currently on awe duty. Upon searching the information data banks of the De ent o(Defense Manpower Data Center" based on the ' i that you provided, the abo4^e its the current stag of the mividual as to al branches of the Miktamy. )t)jtjjVt 14 1104goli, in- fi?"- MaryM. Snavely-Ikon, Director Department of Defense - Manpower Data Centex 1600 WIum Bh*d_ Suite 400 An n, VA 22209-2593 The Defense Manpower Data Centex (DINIDC) is an organkafion of the Department of Defense that firms the Defense Enrollment and EligW Repofting System (DEERS) database which is the official source of"data on efigW for nary medical care and other el o ty systems. The Deparbmtof Defense strongly supports the enfixcement of &e Servktmembers Civil Relief Act 150 USCS Appx. §§ 301 et seq] (SCRA) (formerly the Sommers' and Sailors' Civil Reif Act of 1940)_ l)MDC has issued beds of thcasands of "does not possess any information that the nuim l is currently on active dnty" responses, and has educed a small error rate. In the event the individual referenced above, or any fart>ly member, friend, or representative asserts in any manner that the indivklual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the persoes active duly status by contacting that persons Military Service via the "de fensefxk mil" URL provided bekm. If you have evince the person is on active-duty and your fad to obtains this additioual.Military Service Nwificafim provisions of the SCRA may be invoked against you: If you obtain fia thew infer about the person ( e.g., an SSN. improved accuracy of DOB. a middle name.)" you can suit your requrest again at this Web site and we ikil provide a new certificate for that querry. This response reflects current active duty status only. For historical ' infiarmatim, please contact the Military Service SC RA point s- of-contact. See: bttt). Jwvvw.de seliuk.Mil ci?tjisl C09SLDR.htaal WARNING-'This certificate was prod based on a name and Soul Security number (SSN) provided by the requester. Providing an erroneous name or SSI u cause an erroneous cemfificate to be provided. RapertMBL?.alJlt'L 7SLY 194818 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY AMERICAN EXPRESS CENTURION BANK ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) VIOLA LIMRIC ) NO. 08-7550 To: VIOLA LIMRIC 317 THIRD ST SUMMERDALE, PA 17093 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: February 06, 2009 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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 ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 BAR r1, , DAVIp J. APOTHAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC A Law Firm Engaged in Debt Collection 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff Attorney ID #38423 A% SHERIFF'S RETURN - REGULAR lr r? CASE NO: 2118-0'7550 P COMMONWEALTH OF PENNSYLVANIA: COUN OF CUMBERLAND ?? 21 r'?MAERICAN EXPRESS CENTURION ;, I FE UP r , VS Gy- LIMRIC VIOLA - -w --- _ VALERIE WEARY Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon LIMRIC VIOLA the DEFENDANT , at 1144:00 HOURS, on the 6th day of ?januaa_ 2009 at 317 T=D STREET SUMMERDALE, PA 17093 by handing to VIOLA LIMBIC a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents there-of. Sheriff's Costs: Docketing Service Af`idavit Surcharge Sworn and Subscibed to before me this 0r 14.00 So Answers : ? AV 14.40 .0Q 10.00 R. Thomas Kline .00 _ 42.40 01/07/2009 APOTHAKER & ASSOCIATES day Deputy Sheriff f A. D. Rl FD--C,' FCE OF THc PRO L ! i?I GARY 2009 AUG 19 PH 3: 21 CUB , U%Ty :11q.0o Pd.a `Ylee?e ,,.fie