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Home My WebLink About09-7617Our File No.: 233274 APOTHAKER & ASSOCrATES, 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 CENTURION BANK c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. LAXMAN KAPUR 5809 STEPHENS CROSSING MECHANICSBURG, PA 17050 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 09- 111017 eAVII-Ferrm 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.: 233274 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 CENTURION BANK c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. LAXMAN KAPUR 5809 STEPHENS CROSSING MECHANICSBURG, PA 17050 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: O q- 7&1,7 C't'? d T1. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is AMERICAN EXPRESS CENTURION BANK c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are LAXMAN KAPUR, an adult individual residing at 5809 STEPHENS CROSSING MECHANICSBURG, PA 17050. 3. At the special instance and request of Defendant, Plaintiff, AMERICAN EXPRESS CENTURION BANK, issued to Defendant(s), Account #3715-678466-01002. 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 $23,391.49. 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 $23,391.49 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSO ES, P.C. Attorney for aint' A Law Firm Enaaae in D t Collection BY: David J. A Dated: 10/30/2009 Our File No.: 233274 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 be ' . The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 04 r ating to unsworn falsification to authorities. David J. Apothaker, Esquire Attorney for Plaintiff DATE: 10/30/2009 AMERICAN EXPRESS CENTURION BANK LAXMAN KAPUR 5809 STEPHENS CROSSING MECHANICSBURG, PA 17050 STATEMENT OF ACCOUNT Debtor's Name: LAXMAN KAPUR Account Number: 3715-678466-01002 Balance Due: $23,391.49 Our File No.: 233274 EXHIBIT "A" 0 FILEF' P C'E . 7F&q ,77:E y 2009 NOY -4 H", 2: 5: -# '78.50 PQ A-nl a.3a441? SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Thomas Kline FILED-CIFFICE Sheriff THE Pf tOT'O `OTARY Ronny R Anderson Chief Deputy 2009 NOV {9 PM 12: S9 Jody S Smith Civil Process Sergeant ' ' ° f c ' `°•'?` CUMBEIV ?`L) `" LINTY PDASYLVANA Edward L Schorpp Solicitor American Express Centurion Bank I Case Number vs. 2009-7617 Laxman Kapur SHERIFF'S RETURN OF SERVICE 11/17/2009 08:15 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on November 17, 2009 at 2015 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Laxman Kapur, by making known unto Roopali Kapur, wife of defendant al 5809 Stephens Crossing 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 November 18, 2009 SWE R THOMAS KLINE, SHERIFF By Depu Sheriff'- (e'; Co,mtpS?ite She.rff. Teieosott. Inc.