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Home My WebLink About09-2369Our Pile No:: 204295 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. RYCKITTA M SHORT 1015 KENT DR MECHANICSBURG, PA 17050-7608 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: pQ - ol-%i GIV61 tar-r1 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:' 204295 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. RYCKITTA M SHORT 1015 KENT DR MECHANICSBURG, PA 17050-7608 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 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 RYCKITTA M SHORT, an adult individual residing at 1015 KENT DR MECHANICSBURG, PA 17050-7608. 3. At the special instance and request of Defendant, Plaintiff, FIA CARD SERVICES, N.A., issued to Defendant(s), Account #4888931993462154. 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 $25,878.91. 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 $25,878.91 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & AS C S, P.C. Attorney fo lain ff A Law Finn Engag in D t Collection BY: David J. Dated: 4/8/2009 Our File No.: 204295 VERIFICATION David J. Apothaker Esquire Esa 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 The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C to unworn falsification to authorities. David J. Apothaker, Esquire Attorney for Plaintiff DATE: 4/8/2009 FIA CARD SERVICES, N.A. RYCKITTA M SHORT 1015 KENT DR MECHANICSBURG, PA 17050-7608 STATEMENT OF ACCOUNT Debtor's Name: RYCKITTA M SHORT Account Number: 4888931993462154 Balance Due: $25,878.91 Our File No.: 204295 EXHIBIT "A" O ?L?t?FF?t'?G ? 2009 APP' 15 AMtt: 42 .478.5o Po ATT%t i* as,sq'lv Sheriffs Office of Cumberland County R Thomas Kline ,1rtitr at 'Cumbrcf? Edward L Schorpp Sheriff Solicitor Ronny R Anderson! Jody S Smith Chief Deputy 0MC6 OF r"E $HEPIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/20/2009 12:11 PM - Brian Barrick, Corporal, who being duly sworn according to law, states that on April 20, 2009 a 1211 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Ryckitta Short, by making known unto Ryckitta Short personally, at One Courthouse Square, Room 303, Carlisle, Cumberland County, Pennsylvania, 17013, its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $28.00 April 21, 2009 SO ANSWERS, R THOMAS KLlNE, SHERIFF rpora Docket No. 2009-2369 FIA Card Services v Ryckitta SHort OF THE P"" ?,IOTA?Y 2099 APR 24 Pik 3: C 11111•111110.1 111111•11.11M1 GORDON & WEINBERG, P.C. BY: FREDERIC I. WEINBERG, ESQUIRE Identification No.: 41360 JOEL M. FLINK, ESQUIRE Identification No.: 41200 1001 E. Hector Street, Ste 220 Conshohocken, PA 19428 484/351-0500 217198 i'lLED-M7'/CE PROTHONOTAF'T NAIR 10 ANN; 16 CUMBERLAND COUNTY PENNSYLVANIA FIA CARD SERVICES, N.A. VS. RYCKITTA M SHORT COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO. : 09-2369 ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of the plaintiff in the above-captioned matter. P012 GORDON & WEINBERG, P.C. BY: FREDERI WEINBERG, ESQUIRE JOEL M. INK, ESQUIRE Attorney for Plaintiff CERTIFICATION OF SERVICE I, FREDERIC I. WEINBERG, ESQUIRE, hereby certify that I, on the date below, served a copy of the Substitution of Attorney and Entry of Appearance Pursuant to Pa.R.C.P. 1028(c)(1), via First Class Mail, postage pre-paid, to all other parties or their counsel of record. FREDERI 1IEINBERG, ESQUIRE Dated: