The URL can be used to link to this page

Home My WebLink About09-4375Our File No.: 215998 ''APOfHAKER& 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. STEPHEN SCHUBACK 312 BRIDGE ST NEW CUMBERLAND, PA 17070-2166 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: o ?v 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.: 215998 APOYHAKER.& 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. STEPHEN SCHUBACK 312 BRIDGE ST NEW CUMBERLAND, PA 17070-2166 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 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 STEPHEN SCHUBACK, an adult individual residing at 312 BRIDGE ST NEW CUMBERLAND, PA 17070-2166. 3. At the special instance and request of Defendant, Plaintiff, AMERICAN EXPRESS CENTURION BANK, issued to Defendant(s), Account #3739-627149-94001. 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 $10,980.20. 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 $10,980.20 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER &,A'SI30CIATES, P.C. A Law Firm EnAa?4ecV in BY: David J. A?othaker, Esquire Dated: 6/23/2009 Our File No.: 215998 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 true and correct to the best of my knowledge, therein are made subject to the penalties of 18 Pa.C belief. The undersigned understands that the statements relating to unsworn falsification to authorities. David J. Apothaker, Esquire Attorney for Plaintiff DATE: 6/23/2009 AMERICAN EXPRESS CENTURION BANK STEPHEN SCHUBACK 312 BRIDGE ST NEW CUMBERLAND, PA 17070-2166 STATEMENT OF ACCOUNT Debtor's Name: STEPHEN SCHUBACK Account Number: 3739-627149-94001 Balance Due: $10,980.20 Our File No.: 215998 EXHIBIT "A" 0 CIF THE . Apy 2099 AA 30 q. 0 -) $,18.5o Po ATN 139 A 5 P? a.a?3'78 R Thomas Kline Sher Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor Sheriffs Office of Cu berland County fill c=:' :..,_ .,~,,_ n~ r~~~ d.°~~~1tr of ~u,nb rt,~y~ '~~ ~a ~,' ~' . _s ~. ~ ~Fn tf~GE i',. jj1~ c..rtIFF ``~}~ _ ^ ~,v. J~ (~! f ~' 4 American Express Centurion Bank vs. Stephen Schuback Case Number 2009-4375 SHERIFF'S RETURN OF SERVICE 07/14/2009 11:12 AM - R. Thomas Kline, Sheriff, who being duly ; diligent search and inquiry for the within named defen locate him in his bailiwick. He therefore returns the w defendant Stephen Schuback. The address requeste PA 17070 is the defendants wife's business of "Tips tc advised the defendant's mail is delivered to address g SherifFs Office on July 14, 2009 stated that he is out c give a current address. The defendant stated he has Road Harrisburg, PA but he does not permanently live attorney's phone number to contact about complaint. SHERIFF COST: $48.30 July 14, 2009 worn according to law, states that he made a cant to wit: Stephen Schuback, but was unable to :hin Complaint and Notice as not found as to the I for service at 312 Bridge Street New Cumberland, Toes". The New Cumberland Postmaster has ven. Stephen Schuback, defendant called the f town until the end of August, and was unwilling to ~n additional mailing address of 3611 Ridgeway at this location. Defendant was given plantiff ~n exact address is not available. SO ANSWERS, ~y~- ~~ ~~ THOMAS KLINE, SHERIFF Our File No.: 215998 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. STEPHEN SCHUBACK Defendant. OF THE PROTHONOTARY 2010 DEC 10 PM 1: 20 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-4375 CIVIL TERM PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASS CIATES, P.C. Attorneys I P 'ntiff A Law Firm Ens ed in eht Cnllectinr By: David J. Apothaker, Esquire Dated: 12/1/2010 Q inniiiS nni