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Home My WebLink About09-7582Our File No.: 227518 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.: (q _ J15W 0,;,,; 1 (erw, THU G TRAN 1309 BRANDT AVE NEW CUMBERLAND, PA 17070-1534 Defendant. 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.: 2275 18 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. THU G TRAN 1309 BRANDT AVE NEW CUMBERLAND, PA 17070-1534 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: O 9 - 'I5 7-?- { T-?•- 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 THU G TRAN, an adult individual residing at 1309 BRANDT AVE NEW CUMBERLAND, PA 17070-1534. 3. At the special instance and request of Defendant, Plaintiff, FIA CARD SERVICES, N.A., issued to Defendant(s), Account #4800113086677601. 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 $1,371.27. 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 $1,371.27 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & AS CIATES, P.C. Attorney f Pl 'ntiff A Law Firm Enizas d in/Debt Collectim BY: David J. ApWaker, Esquire Dated: 10/26/2009 Our File No.: 227518 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 the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904ing to unsworn falsification to authorities. David J. Ap er, Esquire Attorney r Plaintiff DATE: 10/26/2009 FIA CARD SERVICES, N.A. THU G TRAN 1309 BRANDT AVE NEW CUMBERLAND, PA 17070-1534 STATEMENT OF ACCOUNT Debtor's Name: THU G TRAAN Account Number: 4800113086677601 Balance Due: $1,371.27 Our File No.: 227518 EXHIBIT "A" 0 flLED-OFFICE ,T THE P?" : r, ,l()TAIY 2099 NJ's -2 PP's 3: 40 IN-ly *'X.,,50 PO A-a4 ce* L%819 SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Thomas Kline rF T1 ;;; r ! '! T??F?Y Sheriff at ?u+nbrrf l, tr Ronny R Anderson ??4 Lol 2009 NOY -S P1i 2:12 Chief Deputy r Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor FIA Card Services vs. Thu G. Tran Case Number 2009-7582 SHERIFF'S RETURN OF SERVICE 11/04/2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Thu G. Tran, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Thu G. Tran. Current tenant has resided at 1309 Brandt Avenue New Cumberland, PA 17070 has lived here for over three years. An exact address is not available. SHERIFF COST: $48.30 November 04, 2009 SO ANSWERS, -a R THOMAS KLINE, SHERIFF (GI CountySuite Sheriff, Teleosoft. Inr..