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HomeMy WebLinkAbout09-7334Ottr File No.: 219253 APOTHAKER & ASSOCIATES, P.C. BY: David J. Qpothaker, 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. MICHAEL E STOCKLIN 394 BRICK CHURCH RD ENOLA, PA 17025-2507 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 0q - 7`Z 4 Civil Ie.rrh 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 Ottr File No.: 219253 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. ) COURT OF COMMON PLEAS c/o Apothaker & Associates, P.C. ) CUMBERLAND COUNTY 520 Fellowship Road C306 ) Mount Laurel, NJ 08054 ) NO.: U q. 17 3 3 Y Plaintiff, ) VS. ) MICHAEL E STOCKLIN ) 394 BRICK CHURCH RD ) ENOLA, PA 17025-2507 ) Defendant. ) 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 MICHAEL E STOCKLIN, an adult individual residing at 394 BRICK CHURCH RD ENOLA, PA 17025-2507. 3. At the special instance and request of Defendant, Plaintiff, FIA CARD SERVICES, N.A., issued to Defendant(s), Account #4313035440276574. 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 $6,151.96. 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. r-I Y WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $6,151.96 and rpquests•this Court award costs to the extent permitted by applicable law. APOTHAKER & ASS TES, P.C. Attorney for aint A Law Firm Engaged De t Collec? BY: David J. Dated: 10/15/2009 Our File No.: 219253 VERIFICATION David J. Apothaker Esauire F-, q- 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, belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C. A. 4 04 relatine'ounsworn falsification to authorities. David J. Apotiaker, Esquire Attorney for Plaintiff DATE: 10/15/2009 FIA CARD SERVICES, N.A. MICHAEL E STOCKLIN 394 BRICK CHURCH RD ENOLA, PA 17025-2507 STATEMENT OF ACCOUNT Debtor's Name: MICHAEL E STOCKLIN Account Number: 4313035440276574 Balance Due: $6,151.96 Our File No.: 219253 EXHIBIT "A" 0 OF TH8E'NW'NOM 209 OCT 23 12a 24 78.50 P? ATT-( CIG? 15'5177 Sheriffs Office of Cumberland County R Thomas Kline Sheri Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Low"r st a brr 70 OFFICE OF 7,E SH.RIFF FLED--UTICE OF THE F- %"r'W0N,!0TARY 2009 NOV -6 Pfd 2: 1; 8 Edward L Schorpp Solicitor FIA Card Services Case Number vs. Michael E. Stocklin 2009-7334 SHERIFF'S RETURN OF SERVICE 10/28/2009 11:27 AM - Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on October 28 2009 at 1127 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Michael E. Stocklin, by making known unto himself personally, at 394 Brick Church Road 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: $41.50 SO ANSWERS, toooaesv,g[ l, GP October 29, 2009 R THOMAS KLINE, SHERIFF Deputy Sheriff oavidD. Buell Prothonotary XirkS. Sohonage, ESQ Soricitor Snee X Simpson vt Deputy (Prothonotary Irene E. 5W orrow 2nd Deputy Prrothonotary office of the ftothonotary Cumber(and County, Tennsy(vania Ot%-YWCIVILTERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 30TH DAY OF OCTOBER, 2012, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE - THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P. 230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY (717) 240-6195 0 ('ax (717) 240-6573