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Home My WebLink About09-5905Vj ' f Our File No.: 224669 APOT14AKER & 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. LAURIE SIMMONS 202 WALNUT ST LEMOYNE, PA 17043 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 11111 l -T(V/n 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.: 224669 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. LAURIE SIMMONS 202 WALNUT ST LEMOYNE, PA 17043 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: o 4- 59o? 0,.,;j- Tu... 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 LAURIE SIMMONS, an adult individual residing at 202 WALNUT ST LEMOYNE, PA 17043. 3. At the special instance and request of Defendant, Plaintiff, AMERICAN EXPRESS CENTURION BANK, issued to Defendant(s), Account #3767-805264-01008. 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 $15,792.95. 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 $15,792.95 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & S CIATES, P.C. Attorney red P ntiff A Law Firm Enea Debt Q"ollectioi BY: David J. Apothaker, Esquire Dated: 8/21/2009 Our File No.: 224669 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, information, and therein are made subject to the penalties of 18 Pa.C.S.A. David J. Apc Attorney The undersigned understands that the statements relating to unworn falsification to authorities. ker, Esquire Plaintiff DATE: 8/21/2009 LAURIE SIMMONS 202 WALNUT ST LEMOYNE, PA 17043 AMERICAN EXPRESS CENTURION BANK STATEMENT OF ACCOUNT Debtor's Name: LAURIE SIMMONS Account Number: 3767-805264-01008 Balance Due: $15,792.95 Our File No.: 224669 EXHIBIT "A" ?TAPY 2009 A UG 2 7 PH 3: 31 1od ?l?# fLl?/?13 Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant ??,??si?' of ? a r%r j? p?, f??? OFFICE -,PTH4 S-ERIFF RLED4)1-'F1CE OF THc Pw'?'n`1 ?T,aY 2009 SEP i I AM 8: 4 4 cu S,:cUNTY Edward L Schorpp Solicitor American Express Centurion Bank Case Nu ber vs. Laurie Simmons 2009-905 SHERIFF'S RETURN OF SERVICE 09/04/2009 04:24 PM - Michelle Gutshall, Deputy Sheriff, who being duly sworn according to law, states that on September 4, 2009 at 1624 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Laurie Simmons, by making known unto herself personally, at 2021 alnut Street Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handi g to her personally the said true and correct copy of the same. SHERIFF COST: $42.40 SO ANSWERS, September 08, 2009 R THOMAS KLINE, SHERIFF 1? Deputy Sheriff