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Home My WebLink About09-0173i Our File No.: 196428 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. FRANCIS DERENZO 711 LONGS GAP RD CARLISLE, PA 17013 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Oq - Ol'73 l~ ~ V- l~irvk 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 aze 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 ,~ ~ fJur Filg No.: 196428 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. FRANCIS DERENZO 711 LONGS GAP RD CARLISLE, PA 17013 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY 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 FRANCIS DERENZO, an adult individual residing at 711 LONGS GAP RD CARLISLE, PA 17013. 3. At the special instance and request of Defendant, Plaintiff, AMERICAN EXPRESS CENTURION BANK, issued to Defendant(s), Account #3772-341909-71002. 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 $15,391.10. 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. ,, , Z ,WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $15,391.10 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law APOTHAKER & A 1 Attorney f r P: A Law Firm Engaf~ d in BY: Dated: 12/26/2008 RTES, P.C. David J. Apoth~ker, Esquire Our File No.: 196428 ~~ 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 aze true and correct to the best of my knowledge, information, and therein aze made subject to the penalties of 18 Pa.C.S David J. The undersigned understands that the statements relating to unsworn falsification to authorities. ker, Esquire Plaintiff DATE: 12/26/2008 AMERICAN EXPRESS CENTURION BANK FRANCIS DERENZO 711 LONGS GAP RD CARLISLE, PA 17013 STATEMENT OF ACCOUNT Debtor's Name: FRANCIS DERENZO Account Number: 3772-341909-71002 Balance Due: $15,391.10 Our File No.: 196428 EXHIBIT "A" ~ o'~ ns c~ ... .rte ~ Oo D ~ ~ .~ ~~-, ~ ~' ~~ C C7D --