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Home My WebLink About09-2394? w Our File No.: 204325 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. SCOTT A COLEMAN 1074 HERITAGE AVE SHIPPENSBURG, PA 17257-9267 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 - a344 C4^v i t ?er??- 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 SEA' 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 J w Our Pile No.: 204325 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. ) COURT OF COMMON PLEAS c/o Apothaker & Associates, P.C. ) CUMBERLAND COUNTY 520 Fellowship Road C306 Mount Laurel, NJ 08054 NO.: o q - 2319 Plaintiff, ) VS. ) SCOTT A COLEMAN ) 1074 HERITAGE AVE ) SHIPPENSBURG, PA 17257-9267 ) 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 SCOTT A COLEMAN, an adult individual residing at 1074 HERITAGE AVE SHIPPENSBURG, PA 17257-9267. 3. At the special instance and request of Defendant, Plaintiff, FIA CARD SERVICES, N.A., issued to Defendant(s), Account #4800115996044632. 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 $3,358.76. 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 paymenti of the amount due as above. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $3,358.76 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASSO TES, P.C. Attorney for ' tiff A Law Firm Engag in ebt Collection BY: David J. Ap th , Esquire Dated: 4/8/2009 Our File No.: 204325 VERIFICATION David J. Apothaker Esquire r- 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 li f. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. . 4904 elating to unsworn falsification to authorities. David J. Apothaker, Esquire Attorney for Plaintiff DATE: 4/8/2009 t ?r SCOTT A COLEMAN 1074 HERITAGE AVE SHIPPENSBURG, PA 17257-9267 FIA CARD SERVICES, N.A. STATEMENT OF ACCOUNT Debtor's Name: SCOTT A COLEMAN Account Number: 4800115996044632 Balance Due: $3,358.76 Our File No.: 204325 EXHIBIT "A" 229 APR ; AM /I: ?ulJ, r `` a ' ???4rxW 4''r$ .50 Po A-r-N 0rte IA461 eTtaaaso • Our File No.: 204325 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. SCOTT A COLEMAN Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-2394 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. A Law Firm By: David J. Debt Collection , Esquire Dated: May 4, 2009 FIIED-oFr-tCE OF THE Ppt-THo !OTARY 2009 MAY 14 PM 2: 27