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Home My WebLink About10-1890Our File No.: 247604 APOTHAKER & 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. 655 PAPERMILL ROAD NEWARK, DE 19711 Plaintiff, vs. GLORIA J EDKIN 6405 GLENWOOD ST MECHANICSBURG, PA 17050 Defendant. FILED-OFFICE OF THE pR , , H, itJTRRY 2010 MAR 17 All 11: 31 PLEN 4SYLVA'v, COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 10 1840 NOTICE 01-tv it -Jr'(- M 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 4001.00 AQ *?TN Cv-r l7wgR U1 aA018 a ,, Our File No.: 247604 APOTHAKER & 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. 655 PAPERMILL ROAD NEWARK, DE 19711 Plaintiff, COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. vs. GLORIA J EDKIN 6405 GLENWOOD ST MECHANICSBURG, PA 17050 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 GLORIA J EDKIN, an adult individual residing at 6405 GLENWOOD ST MECHANICSBURG, PA 17050. 3. At the special instance and request of Defendant, Plaintiff, FIA CARD SERVICES, N.A., issued to Defendant(s), Account #4264293273332100. 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 $19,632.82. 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 $19,632.82 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney, fWnbt iff A Law Firm Engage Collection BY: David J. Dated: 3/8/2010 Our File No.: 247604 I 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/t/e1ati g to unworn falsification to authorities. David J. Apothaker, Esquire Attorney for Plaintiff DATE: 3/8/2010 FIA CARD SERVICES, N.A. GLORIA J EDKIN 6405 GLENWOOD ST MECHANICSBURG, PA 17050 STATEMENT OF ACCOUNT Debtor's Name: GLORIA J EDKIN Account Number: 4264293273332100 Balance Due: $19,632.82 Our File No.: 247604 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson L Sheriff ? a1r c4 itnLcr/??? !Ppc '01' al t Jody S Smith Chief Deputy Edward L Schorpp Solicitor €Fi C PL FIA Card Services Case Number vs. 2010-1890 Gloria J. Edkin SHERIFF'S RETURN OF SERVICE 03/18/2010 04:22 PM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on March 18, 2010 at 1622 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Gloria J. Edkin, by making known unto Ronald Leyder, Husband of defendant at 6405 Glenwood Street Apartment #6, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. (I fl d a NjItudj I U H, DEPU SHERIFF COST: $37.00 March 19, 2010 SO ANSWERS, RON ~ R ANDERSON, SHERIFF (ci {;ountySuite Shentt. teleosutt. Inc. (y~1 /~L Our File No.: 247604 COURT OF COMMON PLEAS OF FIA CARD SERVICES, N.A. ) CUMBERLAND COUNTY Plaintiff ) vs. ) NO.: 10-1890-CIVIL TERM GLORIA J EDKIN ) Civil Action c d ~; Defendant ) ~~, ~, ~~~ ~ , ~ ~ .... ~ ~ ~~ ~- ~= ~ rn Y r.._ i.... PRAECIPE FOR LISTING CASE FOR ARGUMENT ~ ~_ ~ ~ ~. z. ~-i~.. - - ~""~ ~- tv ~- .e TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within mar fad the next Argument Court. 1. Matter to be Argued: Defendant's Motion for Judgment of Non-Pros or In the Alternative Defendant's Preliminary Objections to Plaintiff s Amended Complaint. 2. Counsel who will argue cases: Benjamin J. Cavallaro Esauire Attorney for Plaintiff 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 GARY LEYDER Attorney for Defendant 2040 LINGLESTOWN RD STE 202 HARRISBURG, PA 17110 3. I will notify all parties in writing within two days that this case has been listed for argument. 4. Argument Court Date: Next available. APOTHAKER & ASSOCIATES, P.C. Attorney for 'ntiff A Law Firm Engag m ebt Collection BY: Esquire Dated: June 29, 2010 eAlAL Our File No.: 247604 FI,f CARD SERVICES, N.A. Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY ) NO.: 10-1890 CIVIL TERM vs . GLORIA J EDKIN ) Civil Action zrn ? - z?a r Defendant ) 2 3 p PRAECIPE FOR LISTING CASE FOR ARGUMENT -4 c.n --J TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within matter for the next Argument Court. r? x -a rn C) _n CD C-) Matter to be Argued: Defendant's Motion for Judgment of Non-Pros or In the Alternative Defendant's Preliminary Objections to Plaintiff's Amended Complaint. 2. Counsel who will argue cases: Benjamin J. Cavallaro, Esquire Attorney for Plaintiff 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 GARY LEYDER, Esquire Attorney for Defendant 2040 LINGLESTOWN RD STE 202 HARRISBURG, PA 17110 3. I will notify all parties in writing within two days that this case has been listed for argument. 4. Argument Court Date: August 26, 2011. APOTHAKER & ASSOCIATES, P.C. Attorney for Plaintiff A Law Firm Engaged in Debt Collection BY0enjamin Cavallaro, Esquire Dated: July 6, 2011 Our File No.: 247604 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D.# 38423 520 Folowship Road C306 MountLaurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff FIA CARD SERVICES, N.A. Plaintiff, vs. GLORIA J EDKIN FILED-OFFICE OF THE PROTHONOTARY 2011 DEC 27 PM 2: 55 CU PENNS LDVAH A TY COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-1890 CIVIL TERM Defendant. PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER Atto A Law Firm E g By: David J. A ASSOCIATES, P.C. for Plaintiff ;ed in Debt Collection , Esquire Dated: 12/16/2011 01111111111111111 ?