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Home My WebLink About09-2078ti Clur File'No.: 202492 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Fsquire, 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. NORMA P MARTELL A/K/A NORMA PUCCINA 620 BRENTON ST SHIPPENSBURG, PA 17257-2114 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Qq - dprl8 Civil tem 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 t Cur File No.: 202492 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, (squire, 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. ) NORMA P MARTELL A/K/A NORMA ) PUCCINA ) 620 BRENTON ST ) SHIPPENSBURG, PA 17257-2114 ) Defendant. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0,1- a. 0-7 P a4;4 - 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 NORMA P MARTELL A/K/A NORMA PUCCINA, an adult individual residing at 620 BRENTON ST SHIPPENSBURG, PA 17257-2114. 3. At the special instance and request of Defendant, Plaintiff, FIA CARD SERVICES, N.A., issued to Defendant(s), Account #4888938026918953. 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 $9,148.93. 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 $9,148.93 and requests this Court award Plaintiff attorney's fees APOTHAKER & A 1 Attorney f r P: A Law Firm Engag in BY: to the extent permitted by applicable law. TES, P.C. David J. Apothaker, Esquire Dated: 3/30/2009 Our File No.: 202492 f 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 a statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating to unsworn falsification to authorit' s. David J. Ap thaker, Esquire Attorney r Plaintiff DATE: 3/30/2009 4 ? FIA CARD SERVICES, N.A. NORMA P MARTELL A/K/A NORMA PUCCINA 620 BRENTON ST SHIPPENSBURG, PA 17257-2114 STATEMENT OF ACCOUNT Debtor's Name: NORMA P MARTELL AW- A NORMA PUCCINA Account Number: 4888938026918953 , Balance Due: $9,148.93 Our File No.: 202492 EXHIBIT "A" `..J y M, Ft Q A 2009 APR -2 PM f : 25 CVM&: ?f- rr1{ a1, irL?lY? ! PE,,NN LVA* $'T8. so Po ATW ct:ro? tas3o1 RT'# 'U3149 Sheriffs Office of Cumberland County R Thomas Kline ?,.?ea' eat 4iugbrr44 Edward L Schorpp Sheriff Solicitor Ronny R Anderson Jody S Smith Chief Deputy O{rIer '"E >-ER)CF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/17/2009 01:06 AM - Valerie Weary, Deputy Sheriff, who being duly sworn according to law, states that on April 17, 2009 at 1640 hours, she served a true copy of the within Complaint and Notice, upon the within named .defendant, to wit: Norma P. Martell, by making known unto Natailia Delarosa-Martell, daughter of defendant, at 620 Brenton Street, Shippensburg, Cumberland County, Pennsylvania, 17257, its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $62.20 SO ANSWERS, April 21, 2009 R THOMAS KLINE, SHERIFF Deputy Sheriff Docket No. 2009-2078 FIA Card Services v Norma Martell C Our File No.: 202492 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. COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, VS. NORMA P MARTELL A/K/A NORMA PUCCINA NO. 09-2078 Defendant. PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASS IATES, P.C. Attorneys f 1 'tiff A Law Firm Eng d ' ebt Collection By: David J. Apothaker, Esquire Dated: 5/15/2009 20fj 9 1.1 Y 22 F 29 t