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