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Home My WebLink About10-1026Our File No.: 246295 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 BANK, FSB c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. STANLEY MACK 2307 CLARIDGE CT ENOLA, PA 17025 Defendant. 1 RLEn?Dt.?-0IFFICE THE 2010 FEB -9 Ali IG: 52 L?F? e :LJ .?il1R?t i? COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: !O - 16jG (2*%vi t (erne 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 ("J $ga.oo Pp A-MY m* I(o845k Our Fide No.: 246295 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 BANK, FSB c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. STANLEY MACK 2307 CLARIDGE CT ENOLA, PA 17025 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 6 jo-)bc?-? a-v, 44tA CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is AMERICAN EXPRESS BANK, FSB c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are STANLEY MACK, an adult individual residing at 2307 CLARIDGE CT ENOLA, PA 17025. 3. At the special instance and request of Defendant, Plaintiff, AMERICAN EXPRESS BANK, FSB, issued to Defendant(s), Account #3782-638266-42009. 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 $27,763.88. 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 $27,763.88 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney for Plaintiff .A Law Firm Enizazed71n Debt Collection BY: David J1 Aio l&er, Esquire Dated: 1/26/2010 Our File No.: 246295 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, therein are made subject to the penalties of 18 Pa.C belief. The undersigned understands that the statements relating to. unsworn falsification to authorities. David J Apothaker, Esquire Attorney for Plaintiff DATE: 1/26/2010 %' AMERICAN EXPRESS BANK, FSB STANLEY MACK 2307 CLARIDGE CT ENOLA, PA 17025 STATEMENT OF ACCOUNT Debtor's Name: STANLEY MACK Account Number: 3782-638266-42009 Balance Due: $27,763.88 Our File No.: 246295 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Fj~-E~~ ~ ~ r'~c /~~~/ ~~- ~ ~r { a 'i"'ttri 1 Sheriff {.... T °~t r, ._ _ ,, ~, y ~~~~~ttr ~i 4:u~r+G~t•1~~~~ L~ i ti F~U ~ 7 f-~~`l ~ ~ v 1 Jod S Smith Chief Deputy Edward L Schorpp r~ 4,- :.. ~~?-,,~ Solicitor ~ ~~ r _ ~. American Express Bank, FSB vs. Case Number Stanley Mack 2010-1026 SHERIFF'S RETURN OF SERVICE 02/17/2010 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Stanley Mack, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Stanley Mack. Marie Huben, current resident of 2307 Claridge Court, Enola, PA 17025 and the defendants girlfriend, advised Deputies Stanley Mack is residing at 1019 Kent Gardens, Lititz, PA 17543. SHERIFF COST: $46.50 February 17, 2010 SO ANSWERS, R ANDERSON, SHERIFF (C i,0i.ln'ySiliCe J'!1P, I1`r1', '(~2~..3ti`I. lnC.