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Home My WebLink About09-6338 Our File No.: 227876 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 BANK, FSB c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. JOSH SCHOENLY 5805 FAWN MEADOW LN ENOLA, PA 17025 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: OQ - (0338 0,tv; l Ie,, NOTICE You have been sued in court. If you wish to defend against the claims set forth in the foll you must take action within twenty (20) days after this complaint and notice are served, by enter appearance personally or by attorney and filing in writing with the court your defenses or obi claims set forth against you. You are warned that if you fail to do so the case may proceed with judgment may be entered against you by the court without further notice for any money cl complaint or for any other claim or relief requested by the plaintiff. You may lose money or pro rights important to you. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU DO N LAWYER OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH FIND OUT WHERE YOU CAN GET LEGAL HELP. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY BE ABLE T YOU WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES T PERSONS AT A REDUCED FEE OR NO FEE. CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE ing pages, a written ons to the you and a ted in the v or other HAVE A LOW TO PROVIDE ELIGIBLE CARLISLE, PA 17013 717-249-3166 Our File No.: 227876 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road7C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff AMERICAN EXPRESS BANK, FSB c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. JOSH SCHOENLY 5805 FAWN MEADOW LN ENOLA, PA 17025 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 09- 6338 &?-d 14?11 CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is AMERICAN EXPRESS BANK, FSB c/o Apothaker & Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are JOSH SCHOENLY, an adult individual residing at 5805 FA LN ENOLA, PA 17025. 3. At the special instance and request of Defendant, Plaintiff, AMERICAN FSB, issued to Defendant(s), Account #3727-320943-51002. 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 $21,000.98. A 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 included in Exhibit "A". 7. Although demand has been made, Defendant(s) has failed to make payment of the P.C., 520 MEADOW SS BANK, and correct and are due as above. . WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $21,000.98 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney for Pl ' tiff A Law Firm Engaged i)bt Collection BY: Dated: 9/17/2009 David J. Our File No.: 227876 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 belief The undersigned understands that he statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating to unsworn falsification to auth rities. David J. A Oaake , Esquire Attorne for Plaintiff DATE: 9/17/2009 AMERICAN EXPRESS BANK, FSB JOSH SCHOENLY 5805 FAWN MEADOW LN ENOLA, PA 17025 STATEMENT OF ACCOUNT Debtor's Name: JOSH SCHOENLY Account Number: 3727-320943-51002 Balance Due: $21,000.98 Our File No.: 227876 EXHIBIT "A" OF 7Hr: c'ar' .' `OTAPY 20,39 SEE 23 PH 2: ? or- ex it 151+F0.'? e a3oq s9 Sheriff s Office of Cumberland County R Thomas Kline ~r ~_:1 Sheriff ~$~`a;, of tu,uGrrl,~~r~ ~~~ rF ~ a"' .'y -;j~V Ronny R Anderson Chief Deputy ~~`~ ~;,=`n ~. j ~r~ ..t ~~ „ ~ . `" ~ iii': C' • ~.! 'v1 Jody S Smith Civil Process Sergeant oef ` ~ ~"r '"~~~`"' ' Cr.1'E.. r'ru. Edward L Schorpp j - ~ ~ ~ E Solicitor American Express Bank, FSB Case Number vs. 2009-6338 Josh A. Schoenly SHERIFF'S RETURN OF SERVICE 09/25/2009 10:43 AM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on September 25, 2009 at 1043 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Josh A. Schoenly, by making known unto himself personally, at 5805 Fawn Meadow Lane Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $42.40 September 25, 2009 SO ANSWERS, ~.J R THOMAS KLINE, SHERIFF Dep eriff