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Home My WebLink About09-2077t)ur Fife No.: 193001 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, N.A. c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. CARA L KAUFFMAN 221 S 5TH ST LEMOYNE, PA 17043-1804 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. Cq - o10'T 7 NOTICE aiva lej-P., 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 tour Fire No.: 193001 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, N.A. c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. CARA L KAUFFMAN 221 S 5TH ST LEMOYNE, PA 17043-1804 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 9- 020 q 7 044?-,( ??-- CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is FIA CARD SERVICES, N.A. c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are CARA L KAUFFMAN, an adult individual residing at 221 S 5TH ST LEMOYNE, PA 17043-1804. 3. At the special instance and request of Defendant, Plaintiff, FIA CARD SERVICES, N.A., issued to Defendant(s), Account #4888930069535232. 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 $4,767.08. 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 $4,767.08 and requests this Court award Plaintiff attorney's fees 54 costs to the extent permitted by applicable law. APOTHAKER & SS CIATES, P.C. Attorney or aintiff ,,,??- A Law Firm Enga ed i Debt.Q'nllectini BY: Dated: 3/30/2009 11 - David J. Apothaker, Esquire Our File No.: 193001 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 the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating to unworn falsification to David J. Akttaker, Esquire Attorney for Plaintiff DATE: 3/30/2009 CARA L KAUFFMAN 221 S 5TH ST LEMOYNE, PA 17043-1804 FIA CARD SERVICES, N.A. STATEMENT OF ACCOUNT Debtor's Name: Account Number: Balance Due: Our File No.: 193001 CARA L KAUFFMAN 4888930069535232 $4,767.08 EXHIBIT "A" of nr ?Aft 219 APP -2 PM 1: 24 cum ?c aC COUNTY P R YW* $'78.So PA Arty CIL* I&% Lfa` 2,2314 $ R Thomas Kline Sheriff Ronny R Anderson Chief Deputy s Office of Cumberland County d.°??tr Ot ?ltutbrr??h? OFFICE CAF T-E S-ERIFF Edward L Schorpp Solicitor Jody S Smith Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/06/2009 05:04 AM - Shawn Harris 2009 at 1704 hours, he si defendant, to wit: Cara L. Street, Lemoyne, Cumbe him personally the said tr SHERIFF COST: $42.40 April 07, 2009 Docket No. 2009-2077 Fia Card Services v Cara Deputy Sheriff, who being duly sworn according to law, states that on April 6, ed a true copy of the within Complaint and Notice upon the within named Iuffman by making known unto Cara L. Kauffman personally, at 221 S. 5th id County, Pennsylvania, 17043 its contents and at the same time handing to and correct copy of the same. SO ANSWER 1011-Y NE, SHERIFF RLED-OFRCE of THE P"'^ 'ONOTIRY 2009 APR -9 PM 2= 16 ^3run ; r^S,+ `fir ??,,, Our File No.: 193001 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, N.A Plaintiff, VS. COURT OF COMMON PLEAS CUMBERLAND COUNTY CARA L KAUFFMAN Defendant. NO. 09-2077 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys for tiff A Law Firm Enizag in ebt Collection By: David J. Apothaker, Esquire Dated: 5/4/2009 A LEDP :1 '7 2099 MAY 11, Pi =i 2: 2 7