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Home My WebLink About09-7898ti (lur File No.: 237407 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. LAURIE SIMMONS 202 WALNUT ST LEMOYNE, PA 17043 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Oq-78g8 Civil lerM 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.: 237407 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. LAURIE SIMMONS 202 WALNUT ST LEMOYNE, PA 17043 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 q - -7 Fg 8' C?,-.! -rz. 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 LAURIE SIMMONS, an adult individual residing at 202 WALNUT ST LEMOYNE, PA 17043. 3. At the special instance and request of Defendant, Plaintiff, AMERICAN EXPRESS CENTURION BANK, issued to Defendant(s), Account #3717-583817-22002. 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 $11,476.18. 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 $11,476.18 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney for Plaintiff A Law Firm Engaged i,Debt Collection BY: Dated: 11/4/2009 David J. Apt ;ake'r, Esquire Our File No.: 237407 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. 4904 relating to unworn falsification to authorities. David J. Apotaker, Esquire Attorney for Plaintiff DATE: 11/4/2009 ' AMERICAN EXPRESS CENTURION BANK LAURIE SIMMONS 202 WALNUT ST LEMOYNE, PA 17043 STATEMENT OF ACCOUNT Debtor's Name: LAURIE SIMMONS Account Number: 3717-583817-22002 Balance Due: $11,476.18 Our File No.: 237407 EXHIBIT "A" FLr ?J r 2009 EN 13 AV-1 9: 516 stogy SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor C OFFICE '"E $-ERIFF FILED-40FFiCE OF THc P°0-1 HDJOTARY American Express Centurion Bank vs. Laurie Simmons 2009 NOY 19 PH 12: 5 7 CUMt 1:!,L 1; '-UNTY PoNNSYLVANIA Case Number 2009-7898 SHERIFF'S RETURN OF SERVICE 11/16/2009 06:51 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on November 16, 2009 at 1851 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Laurie Simmons, by making known unto herself personally, at 202 Walnut Street Lemoyne, Cumberland County, Pennsylvania 17043 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $42.40 November 17, 2009 SO ANSWERS, JOO R THOMAS KLINE, SHERIFF AaSohlrifi !C Coun?ySuite Shenff, IeleosoR Inc.