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Home My WebLink About10-1808.*.Our Ne No.: 243267 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D. #39423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff FIA CARD SERVICES, N.A. 655 PAPERMILL ROAD NEWARK, DE 19711 Plaintiff, VS. JOHN H WIMBROUGH 1913 BALDWIN CT MECHANICSBURG, PA 17055 Defendant. ." G t r- K A_ ,?- 2010 MAR 12 PH I: 15) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 10 - 1808 NOTICE 0'i vitTry 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 Q) 40.00 Pa A-MY cet f ) a Slag erg' a 33 Sao • Our-File No.: 243267 APbTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D. #38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff FIA CARD SERVICES, N.A. ) COURT OF COMMON PLEAS 655 PAPERMILL ROAD ) CUMBERLAND COUNTY NEWARK, DE 19711 ) NO.. Plaintiff, ) VS. ) JOHN H WIMBROUGH ) 1913 BALDWIN CT ) MECHANICSBURG, PA 17055 ) Defendant. ) CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is FIA CARD SERVICES, N.A., 655 PAPERMILL ROAD, NEWARK, DE 19711. 2. Defendant(s) is/are JOHN H WIMBROUGH, an adult individual residing at 1913 BALDWIN CT MECHANICSBURG, PA 17055. 3. At the special instance and request of Defendant, Plaintiff, FIA CARD SERVICES, N.A., issued to Defendant(s), Account #74982999517410. 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 $31,537.57. 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 $31,537.57 and requests this Court award costs to the extent permitted by applicable law. Dated: 3/4/2010 APOTHAKER & ASSOCIATES, P.C. Attorney for Plaintiff A Law Firm Ened in Debt Collection BY: David Esquire Our File No.: 243267 VERIFICATION David J. Apothaker Esquire Esa 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, an4 belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A/J904 relating to unworn falsification to authorities. David J. Ap Attorney Esquire DATE: 3/4/2010 FIA CARD SERVICES, N.A. JOHN H WIMBROUGH 1913 BALDWIN CT MECHANICSBURG, PA 17055 STATEMENT OF ACCOUNT Debtor's Name: JOHN H WIMBROUGH Account Number: 74982999517410 Balance Due: $31,537.57 Our File No.: 243267 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson , Sheriff Jod S Smith ~~~ytirr at ~ei,~,t~rrr~~~b ~~-~~'rlv Chief Deputy ('±~ ~« ~-,n,, ~ ~-, , `;~TA,4Y Edward L Schorpp Zn (~ ~ ~, ;. ~ ~ l;;~j + ~ ; ~ Solicitor ~~~ , . ~~:~w~ ,- ; ; FIA Card Services Case Number vs. John H. Wimbrough 2010-1808 SHERIFF'S RETURN OF SERVICE 03/19/2010 04:39 PM -Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on March 19, 2010 at 1639 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: John H. Wimbrough, by making known unto Kathleen Wimbrough, Wife of defendant at 1913 Baldwin Court, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.00 March 22, 2010 ~ 1 L A ANDA COBAUGH, DEP SO ANSWERS, RON R ANDERSON, SHERIFF ~ ~OU"If t `:^2rtt [Ei;)oDfl fnG. J , 2171839 GORDON & WEINBERG, P.C. BY: FREDERIC I . WEINBERG, ESQUIRE Identification No. : 41360E JOEL M. FLINK, ESQUIRE Identification No. : 41200 - - -�; ggg 1001 E. Hector Street, Ste 220 C, ,` Conshohocken, PA 19428 f�G 484/351-0500 FIA CARD SERVICES, N.A. COURT OF COMMON PLEAS EEE CUMBERLAND COUNTY omm moo vs . DOCKET NO. : 10-1808 CIVIL TERM ERE EME JOHN H WIMBROUGH m▪om °— ENTRY OF APPEARANCE MM- E TO THE PROTHONOTARY: 000 Kindly enter my appearance on behalf of the plaintiff in the m▪mm mom mEN above-captioned matter. oom mom GORDON & WEINBERG, P. C. omm m▪mm Egg EME BY: oom FREDERIC . WEINBERG, ESQUIRE JOEL M. FLINK, ESQUIRE Attorney for Plaintiff P012 1 CERTIFICATION OF SERVICE I, FREDERIC I . WEINBERG, ESQUIRE, hereby certify that I, on the date below, served a copy of the Substitution of Attorney and Entry of Appearance Pursuant to Pa. R.C. P. 1028 (c) (1) , via First Class Mail, postage pre-paid, to all other parties or their counsel of record. /� / FREDE' I. INBERG, ESQUIRE Dated: /��f