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Home My WebLink About09-3081Our File No.: 210776 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. RICHARD NEGLEY 8 OAKHILL RD #T-456 CARLISLE, PA 17015 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: OR - 3081 0"ty"t Tern, 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.: 210776 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. RICHARD NEGLEY 8 OAKHILL RD #T-456 CARLISLE, PA 17015 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Gt?"l CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is AMERICAN EXPRESS CENTURION BANK c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are RICHARD NEGLEY, an adult individual residing at 8 OAKHILL RD #T- 456 CARLISLE, PA 17015. 3. At the special instance and request of Defendant, Plaintiff, AMERICAN EXPRESS CENTURION BANK, issued to Defendant(s), Account #3712-733453-11009. 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 $17,687.21. 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 $17,687.21 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASS IATES, P.C. Attorney fo 1 'tiff A Law Firm Engag d in ebt Collection BY: David J. A4o)fial , Esquire Dated: 5/6/2009 Our File No.: 210776 VERIFICATION David J. Apothaker, Esquire Es4. 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 that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4404 rilating to unsworn falsification to authorities. David J. Apot er, Esquire Attorney for aintiff DATE: 5/6/2009 . !. • • _a RICHARD NEGLEY 8 OAKHILL RD #T-456 CARLISLE, PA 17015 AMERICAN EXPRESS CENTURION BANK STATEMENT OF ACCOUNT Debtor's Name: RICHARD NEGLEY Account Number: 3712-733453-11009 Balance Due: $17,687.21 Our File No.: 210776 EXHIBIT "A" FlU E + 0t=I-- JC, F OF THE '?'+^!'rAAY' 2009 NA y ; 4 PM 2: 13 Cuv Ily 61 % . So Pa ATTY C& 1-616LOI ff*dasi3) Sheriffs Office of Cumberland County R Thomas Kline Sheri Ronny R Anderson Chief Deputy b?,tq of CUM* rr?? Edward L Schorpp Solicitor Jody S Smith OFFICE E'F 7HE S"=a'FF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05/19/2009 05:45 M -Steve Bender, Deputy Sheriff, who being duly sworn according to law, states that on May 19, 2009 a 1745 hours, he served a true copy of the within Complaint and Notice, upon the within named defend nt, to wit: Richard Negley, by making known unto himself personally, defendant at 8 Oak Hill Road Carlisl , Cumberland County, Pennsylvania 17015 its contents and at the same time handing to him person Ily the said true and correct copy of the same. SHERIFF COST: May 20, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF p y Sheriff 2009-3081 American v 'Richard Neal ey n,,a -c, t rt ..i G"i Our File No.: 210776 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 ) Plaintiff, ) vs. ) RICHARD NEGLEY ) Defendant. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-3081 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorne r Plaintiff A Law Firm E gag in Debt Collection By: David J.~pothaker, Esquire Dated: July 30, 2009 ~ l L~UJ Fi~.J'J ` t (ICY L'3.' ~i t "tli ~L/I ''c A