The URL can be used to link to this page

Home My WebLink About09-2169v ?? Our file No.: 205870 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. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0Q - a l (pq aivi l (&,V* GARY CHRONISTER 4989 E AMELIAS PATH MECHANICSBURG, PA 17050 Defendant. 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 4 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 00 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 I- ,. r Our Bile No.: 205870 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. GARY CHRONISTER 4989 E AMELIAS PATH MECHANICSBURG, PA 17050 Defendant. COURT OF COMMON PLEAS 1 CUMBERLAND COUNTY NO.: (79• al ?9 C- CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is AMERICAN EXPRESS CENTURION BANK c/o Apothaker 4 Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are GARY CHRONISTER, an adult individual residing 'I at 4989 E AMELIAS PATH MECHANICSBURG, PA 17050. 3. At the special instance and request of Defendant, Plaintiff, AMERICAN EXPRESS CENTURION BANK, issued to Defendant(s), Account #3767-304711-71007. 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 $22,95'.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 ?he 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 o Plaintiff and against Defendant(s) for the sum of $22,957.80 and requests this Court award Plaintiff attorney's fee an costs to the extent permitted by applicable law. APOTHAKER & SS IATES, P.C. Attorne for laintiff A Law Firm Ena ize in DebkAC.'ollection BY: Dated: 4/1/2009 David J. Apothaker, Esquire Our File No.: 205870 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 trge and correct to the best of my knowledge, information, and belief The undersigned understand the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating to unsworn falsification to auth tie . David J. Apothacer, Esquire Attorney for Plaintiff DATE: 4/1/2009 t GARY CHRONISTER 4989 E AMELIAS PATH MECHANICSBURG, PA 17050 AMERICAN EXPRESS CENTURION BANK STATEMENT OF ACCOUNT Debtor's Name: Account Number: Balance Due: Our File No.: 205870 GARY CHRONISTER 3767-304711-71007 $22,957.80 EXHIBIT "A" SJ OF PIE PR T ,OTARY 1009 APR -6 Pil 3: 22 p o ATr( ?,-r la8'7Q I Sheriffs Office of Cumberland County Sheriff Kline ('00ta et c unthe'..?, ? Edward L Schorpp 4 Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFiC£ t r?Z SHERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/14/2009 03:30 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on April 14, 2009 at 1530 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Gary Chronister by making known unto Gary Chronister personally, at 4989 Ameilias Path, Mechanicsburg, Cumberland County, Pennsylvania, 17050, its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.90 SO' ANSWER , April 21, 2009 R THOMAS KLINE, SHERIFF De ty S eri Docket No. 2009-2169 American Express v Gary Chronister OF THE "n4rPA CITAPY 2GG9 APR 27 I t : 3 4 Our File No.: 205870 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 AMERICAN EXPRESS CENTURION BANK COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, vs. GARY CHRONISTER Defendant. NO. 09-2169 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & A Law Firm By: ",IATES, P.C. Debt Collection David J. Apothaker, Esquire Dated: April 27, 2009 FILED-OFFICE OF THE PR )rjJr, ,,f0TARY 2009 MAY -8 PM !2: 33 CUPv'E w:, w' ':1i V ! 1 Pr ;taSYLVA4A