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Home My WebLink About09-7332 Ow File No.: 219203 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. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. ---eq, - 73321 DONNA L HAGARMAN 48 RIDGEWAY DR MECHANICSBURG, PA 17050-7974 Defendant. NOTTCF. &CVi(-rem 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.: 219203 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. DONNA L HAGARMAN 48 RIDGEWAY DR MECHANICSBURG, PA 17050-7974 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 04- '733;- &,;1 -f'&,ft-- 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 DONNA L HAGARMAN, an adult individual residing at 48 RIDGEWAY DR MECHANICSBURG, PA 17050-7974. 3. At the special instance and request of Defendant, Plaintiff, FIA CARD SERVICES, N.A., issued to Defendant(s), Account #74974264911154. 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 $25,875.67. 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. 4 WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $25,875.67 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSO S, P.C. Attorney for P ' ti A Law Firm Engaged if Debi Collectio BY: Dated: 10/15/2009 David J. Our File No.: 219203 , 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 eli . The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. 4904 r lating to unswopylalsification to authorities. David J. Apothaker, Esquire Attorney for Plaintiff DATE: 10/15/2009 .P , t FIA CARD SERVICES, N.A. DONNA L HAGARMAN 48 RIDGEWAY DR MECHANICSBURG, PA 17050-7974 STATEMENT OF ACCOUNT Debtor's Name: DONNA L HAGARMAN Account Number: 74974264911154 Balance Due: $25,875.67 Our File No.: 219203 EXHIBIT "A" Q OF nC???a?raTter OCT 23 M 12: 23 ? $78.50 Po AITI ao 155181 0,1&1-519 0. Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy ?,?ttrtitr of ?uurLrr???d "K ALE?-QFICE OF THE P^OTHTARY 1009 OCT 28 AM 9; 42 Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor r E - - r:;E :"ERIFr SUM ', :t ?s "'OUNTY FTENI- W2 ANLA FIA Card Services , vs. Donna L. Hagarman Case Number 2009-7332 SHERIFF'S RETURN OF SERVICE 10/26/2009 06:19 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on October 26, 2009 at 1819 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Donna L. Hagarman, by making known unto herself personally, at 48 Ridgeway Drive Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 October 27, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF BY puty Sheriff