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Home My WebLink About10-1178IN THE COURT OF COMMON PLEAS OF FLED--i_,'rFWE CUMBERLAND COUNTY, PENNSYLVANIA ??^ Tr'- ?`'r'? `' 1O %RY FIA CARD SERVICES, N.A. 201 0 FEB 19 Pill 2: 5 y 655 PAPERMILL ROAD CIVIL ACTION NEWARK, DE 19884 Cam'., Plaintiff r' i f vs. MARK JONES 303 N FAYETTE ST APT 8 SHIPPENSBURG PA 17257-1138 Defendant NO: 10-108 Civil Ic°1-tr? NOTICE TO DEFEND 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 to Defend are served, by entering a written appearance personally or by an 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 ON AGENCIES THAT MAY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT REDUCED FEE OR NO FEE. MIDPENN LEGAL SERVICES 401 EAST LOUTHER STREET CARLISLE, PA 17013 717-243-9400 O #q A. oo P o AMY ce 3a (o4 04 ? 37 Bra IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIA CARD SERVICES, N.A. 655 PAPERMILL ROAD NEWARK, DE 19884 VS. CIVIL ACTION Plaintiff MARK JONES 303 N FAYETTE ST APT 8 SHIPPENSBURG PA 17257-1138 Defendant NO: COMPLAINT Plaintiff, FIA CARD SERVICES, N.A. , by and through its attorneys, Edwin A. Abrahamsen & Associates, P.C., complains of the Defendant as follows: 1. Plaintiff, FIA CARD SERVICES, N.A. , (hereinafter "Plaintiff") is a corporation with a principal place of business located at 655 PAPERMILL ROAD NEWARK, DE 19884. 2. The Defendant MARK JONES (hereinafter "Defendant") is an adult individual residing at 303 N FAYETTE ST APT 8 SHIPPENSBURG PA 17257-1138. 3. At all relevant times herein, Plaintiff was engaged in the business of debt purchase and collection. 4. Defendant applied for and received a credit card issued by FIA CARD SERVICES, N.A. with the account number 74975998373868. 5. Use of the FIA CARD SERVICES, N.A. credit card was subject to the terms and considerations of the Cardmember Agreement (hereinafter "Agreement"), a copy of which was sent to the Defendant along with the credit card. 6. Defendant used the FIA CARD SERVICES, N.A. credit card account number74975998373868, for purchases, cash advances and/or balance transfers. 7. The Defendant was mailed account statements relative to the Defendant's use of the subject credit card. 8. The Defendant defaulted under the terms of the Agreement by failing and refusing to make monthly payments on the account as they became due. 9. The account became delinquent November 22, 2008. 10. The total amount due and owing the Plaintiff including interest, is $15,886.23. 11. Pursuant to the terms of the Agreement, Defendant is liable to Plaintiff for court costs. WHEREFORE, Plaintiff requests judgment in its favor and against Defendant in the amount of $15,886.23 plus costs of suit and any other relief as the Court deems just and appropriate. y Edwin A. Abr n & Assoc. Michael F. c Ord, Esquire Attorney I s.: 86285 120 No yser Ave. Scrant A 18504 mrat rd@eaa-law.com Pho :570-558-5510 Fax: 570-558-5511 VERIFICATION I, Michael F. Ratchford, attorney for Plaintiff, FIA CARD SERVICES, N.A. , am fully familiar with the facts set forth in the within Complaint and am authorized to make this Verification on behalf of Plaintiff. I Verify that the facts set forth in the within allegations are true and correct to the best of my knowledge, knowing that any false statements are punishable by law pursuant to 18 C.S.A. 4904. EDIAV A. ABRAHAHSEhi MICHAEL F. RATLWORG HEATHER [-, WOODRUFF ' ALSO A MEI.IBER OF FL BAR November 17, 2009 Cumberland County Sheriffs 1 Court House Sq. Carlisle, PA 17013 THE LAW OFFICE OF MAIN A. AB&kKkALz;EAI & AS` SCUT &S^ PC WWWX-AA-LAW.COM Re: FIA CARD SERVICES, N.A. vs. MARK JONES Our file Nos.: N09-9819 Dear Sheriff: In regard to the above-noted matter, enclosed please find the following: 1. A true and correct copy of the Complaint; 2. The completed form for service; 3. A check for service; 4. A self-addressed return envelope for the return of service. Please serve the named defendant in accordance with the County Rules of Civil Procedure. If you should have any questions or concerns, please do not hesitate to call me at (570) 558-5510. The defendants address is : MARK JONES 303 N FAYETTE ST APT 8 SHIPPENSBURG PA 17257-1138 Thank you for your attention to this matter. Enclosures mfr/MR 120 N KEYSER AVE SCRANTON, PA 18504 (P) 570.558.5510 (F) 570.558.5511 Request for Service R. Thomas Kline, Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph:717.240.639o Fx:717.240.6397 Plaintiff/s: Court Number: ? Expiration Bate: Type of Action: Defendant/s: Serve Upon: Address for Service: State Alternate Address for for Service: State Type of Service: F Adult in Charge (- Personal r Deputize l- Certified Mail Posting **Copy of Court Order Required with Posting** Special Service Instructions: *If service is to be made by deputized service to another county please specify which county* Filing Attorney: Name: EDWIN A AWRABAMSEN & ASSOCIATES, P.C. Address: 120 NORTH K.M-' - AVENUE SCRANTON, 1% 18504 (570) 55&5510 (570-551? State Phone Number: ' SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ~~~~~3ir of ~u~f+tlrrix~ ~:. ~~; -~ ~ r. ~~F;C:ECc 7~G ;..:RIFF Jody S Smith Chief Deputy Edward L Schorpp Solicitor Case Number 2010-1178 FIA Card Services vs. Mark Jones SHERIFF'S RETURN OF SERVICE 02/22/2010 08:37 PM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on February 22, 2010 at 2036 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Mark Jones, by making known unto Alicia Bradley, adult in charge at 303 N. Fayette Street, Apt. 8, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $46.00 February 23, 2010 210 ~~~ ~~ i °i ~~ VL.: 115 ~:.,; ~ .. '`~`\~MI Sf ~~. ROB T BITNER, DEPUTY SO ANS RS, .~ R R ANDERSON, SHERIFF ;c Coun`, Suite Shentl. Teieo oit. Irn:. IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA FIA Card Services, N.A. 655 Papermill Rd. Newark, DE 19884 VS• Mark A. Jones 303 N. Fayette St., Apt. 8 Shippensburg, PA 17257 Civil Division G7 .J _ ~_ j , v ., _~.~ l ~ --t ^ ~ l : ~f ~ e f ~~, ~ NO. 10-1178 ~~ ~: W ~~~ r ~- _ _ s~ ~ -1, .. " ' i I 1 1 ~ ~ SUGGESTION OF BANKRUPTCY To David D. Buell, Prothonotary Please note upon the record that Mark A. Jones, the defendant in the above- captioned action, filed a Voluntary Petition in Bankruptcywith the United States Bankruptcy Court for the Middle District of Pennsylvania at Harrisburg, PA, on, at March 4, 2010, 5:37 o'clock P.M., which petition was docketed to 1-1 0-01 739-MDF. PURSUANT TO THE PROVISIONS OF 11 U.S.C. §362(A), AN AUTOMATIC STAY IS IN EFFECT FOR ALL PROCEEDINGS INVOLVING THE ABOVE-NAMED DEFENDANT. CERTIFICATE OF SERVICE I, Richard L. Bushman, Esquire, attorney for the above captioned defendant in the bankruptcy proceeding before the United States Bankruptcy Court for the Middle District of Pennsylvania, do hereby certify that on the date set forth below I served the within "Suggestion of Bankruptcy" by depositing a copy of the same in the United States Mail, postage prepaid, at Spring Run, Pennsylvania, addressed to the parties or attorney's of record as follows: FIA Card Services, NA 655 Papermill Rd. Newark, DE 19884 Bank of America PO Box 17054 Wilmington, DE 19850 Bank of America PO Box 15026 V1-'iln'~ington, DE 19850 Edwin, Abrahamsen & Associates Michael F. Ratchford 120 North Keyser Ave. Scranton, PA 18504 Date: March 5, 2010 Spring Run, PA [717] 349-7657 USB~ PAM -LIVE -VERSION 3.3.2 United States Bankruptcy Court Middle District of Pennsylvania Notice of Bankruptcy Case Filing A bankruptcy case concerning the debtor(s) listed below was filed under Chapter 7 of the United States Bankruptcy Code, entered on 03/04/2010 at 5:30 PM and filed on 03/04/2010. Mark A Jones 303 N Fayette St Apt. 8 Shippensburg, PA 17257 SSN / ITIN: xxx-xx-3949 The case was filed by the debtor's attorney: Richard L. Bushman PO Box 51 16767 Path Valley Road Spring Run, PA 17262-0051 717 349-7657 The case was assigned case number 1:10-bk-01739-MDF to Judge Mary D France. Page 1 of 1 In most instances, the filing of the bankruptcy case automatically stays certain collection and other actions against the debtor and the debtor's property. Under certain circumstances, the stay may be limited to 30 days or not exist at all, although the debtor can request the court to extend or impose a stay. If you attempt to collect a debt or take other action in violation of the Bankruptcy Code, you may be penalized. Consult a lawyer to determine your rights in this case. If you would like to view the bankruptcy petition and other documents filed by the debtor, they are available at our Internet home page http:/lecf.pamb.uscourts.gov/ or at the Clerk's Office, U.S. Bankruptcy Court, Ronald Reagan Federal Building, PO Box 908, Harrisburg, PA 17108. You may be a creditor of the debtor. If so, you will receive an additional notice from the court setting forth important deadlines. Terrence S. Miller Clerk, U.5. Bankruptcy Court PACER Service Center Transaction Receipt 03/05/201014: ] 5: ] 0 PACER Lo in: Description: rb1272 Client Code: Notice of Search 1:10-bk-U1739- Filin Criteria: MDF Billable Pa es: ~ Cost: ~ 0.08 https://ecf.pamb.uscourts.gov/cgi-bin/NoticeOfFiling.pl? 198906 3/5/2010 OF Cv4, David-D. Buell A. , Renee 7< Simpson Prothonotary y 1s` Deputy Prothonotary �,f -?ten..s-_. ;.1, z u \o„24, o �irkS. Sohonage, ESQ � .�►, <- Irene E. 9klorrow Solicitor 7750 2nd Deputy Prothonotary Office of the Prothonotaiy Cumberland-County, Pennsylvania JO - //ayg CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER, 2013,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 One Courthouse Square • Suite 100 • Carlisle, PA 17013 • (717)240-6195 • 'Fa.x,(717)240-6573