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Home My WebLink About09-2393Crur File-No.: 204375 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. CELIA ELIZABETH LERNER 432 APPLETREE RD CAMP HILL, PA 17011-5127 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. Oa - 01.3 3 evil b0 r V6% 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 Filly No.: 2043 75 APOTHAKER A 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. ) COURT OF COMMON PLEAS c/o Apothaker & Associates, P.C. ) CUMBERLAND COUNTY 520 Fellowship Road C306 Mount Laurel, NJ 08054 ) NO.: 01 - 2 3 93 Plaintiff, ) vs. ) CELIA ELIZABETH LERNER ) 432 APPLETREE RD ) CAMP HILL, PA 17011-5127 ) Defendant. ) 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 CELIA ELIZABETH LERNER, an adult individual residing at 432 APPLETREE RD CAMP HILL, PA 17011-5127. 3. At the special instance and request of Defendant, Plaintiff, FIA CARD SERVICES, N.A., issued to Defendant(s), Account #5490993997318599. 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 $20,998.33. 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 $20,998.33 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER &,KSSOrIATES, P.C. A Law Firm BY: David I Ilpdfhaker, Esquire Dated: 4/8/2009 Our File No.: 204375 VERIFICATION David J. pothaker, Esquire, Esc 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, apd-belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.%.A. 4904 relating to unsworn falsification to authorities. David J Apothaker, Esquire Attorney for Plaintiff DATE: 4/8/2009 ... • . CELIA ELIZABETH LERNER 432 APPLETREE RD FIA CARD SERVICES, N.A. CAMP HILL, PA 17011-5127 STATEMENT OF ACCOUNT Debtor's Name: CELIA ELIZABETH LERNER Account Number: 5490993997318599 Balance Due: $20,998.33 Our File No.: 204375 EXHIBIT "A" 0 L, CD V? 2009 AN 16 Ali 11: 4 0 CUPS: i"I? vl :: Y 1tir?is $jc.5o Po Am Col. 1a9459 tl* aa38 to Sheriffs Office of Cumberland County R Thomas Kline 4,6iotr of c °mbrry?? Edward L Schorpp Sheri Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE OF r ?E SKERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/24/2009 01:23 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on April 24, 2009 at 1323 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Celia Elizabeth Lerner, by making known unto Celia Elizabeth Lerner personally, at 2001 Rupley Road, Apt. 302, Camp Hill, Cumberland County, Pennsylvania, 17011, its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.50 April 27, 2009 Docket No. 2009-2393 FIA Card Services v Celia E. Lerner SO ANSWERS, f A! R THOMAS =LINE, HERIFF 0000- 000:!? Dep Seri Ili r? f'7 FIA CARD SERVICES, N.A. c/o Apothaker & Associates., P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. CELIA ELIZABETH LERNER 432 APPLETREE ROAD CAMP HILL, PA 17011-5127 Defendant 1. ADMIT 2. DENY COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.; 09-2393 Civil Term ANSWER 3. WITHOUT KNOWLEDGE, THEREFORE DENIED 4. WITHOUT KNOWLEDGE, THEREFORE DENIED 5. WITHOUT KNOWLEDGE, THEREFORE DENIED 6. WITHOUT KNOWLEDGE, THEREFORE DENIED 7. WITHOUT KNOWLEDGE, THEREFORE DENIED The attorney for the Plaintiff has not provided me with a signed copy of a contract card holder agreement and/or a promissory note. By way of this answer, I am disputing the validity of this debt. Dated: 05/01/2009 Cc: APOTHAKER & ASSOCIATES, P.C. Attn: David J. Apothaker, Esquire, Esq. Attorney I.D. #38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Your file No.: 204375 5??-0 ` ?- uk- CELIA ELIZ ETH LERNER date 2001 Rupley Road, #302 Camp Hill, PA 17011 FILE D-4j: CE f-FARY 'T THr- 20D9?1 A €: 08 Our File No.: 204375 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. CELIA ELIZABETH LERNER Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-2393 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSO IATES, P.C. Attorneys fo ntiff A Law Firm Engage ebt Collectioi By: David J. Apothaker, Esquire Dated: 6/3/2009 RLED-01,:F E OF THE PROTHONOTAPY 2009 JUN 10 Phi 2: 20 PEININ'S '`L A A li>-