The URL can be used to link to this page

Home My WebLink About10-2036Our File No.: 254681 APOTHAKER & ASSOCIATES, P.C. BY: David J. ApothaVer, Esquire Attorney I.D. #38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff AMERICAN EXPRESS CENTURION BANK 4315 S 2700 WEST SALT LAKE CITY, UT 84184 Plaintiff, vs. THOMAS HOBBS 733 COLONIAL CT MECHANICSBURG, PA 17050 Defendant. FLEMrTE OF 11-',1: F'?C1TH11?'CTkPY 2010Mf-R 23 AN 10: 14 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 10 - a03(o 0,IVi l (erm 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 G 0.1.00 PO ATM arct 1739'87 w asg3 o Our File No.: 254681 APOTHAKER & ASSOCIATES, P.C. BY: David J.'Apotha7ker, Esquire Attorney I.D. #38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff AMERICAN EXPRESS CENTURION BANK 4315 S 2700 WEST SALT LAKE CITY, UT 84184 Plaintiff, vs. THOMAS HOBBS 733 COLONIAL CT MECHANICSBURG, PA 17050 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is AMERICAN EXPRESS CENTURION BANK, 4315 S 2700 WEST, SALT LAKE CITY, UT 84184. 2. Defendant(s) is/are THOMAS HOBBS, an adult individual residing at 733 COLONIAL CT MECHANICSBURG, PA 17050. 3. At the special instance and request of Defendant, Plaintiff, AMERICAN EXPRESS CENTURION BANK, issued to Defendant(s), Account #3725-525691-81001. 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 $5,314.69. 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 $5,314.69 and'requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney fo aintiff A Law Firm Engage'd id CoIlectioi BY: Dated: 3/15/2010 David J. ApNthaker, Esquire Our File No.: 254681 . , - . 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,*lating to unsworn falsification to authorities. David J. Apothak6r, Esquire Attorney for Plaintiff DATE: 3/15/2010 AMERICAN EXPRESS CENTURION BANK THOMAS HOBBS 733 COLONIAL CT MECHANICSBURG, PA 17050 STATEMENT OF ACCOUNT Debtor's Name: THOMAS HOBBS Account Number: 3725-525691-81001 Balance Due: $5,314.69 Our File No.: 254681 EXHIBIT "A" Our File No.: 254681 AMERICAN EXPRESS CENTURION BANK ) Plaintiff ) vs. ) ) THOMAS HOBBS ) Defendant ) Esq., and PRAECIPE FOR APPOINTMENT OF ARBITRATORS ~ - ~ d•..> TO THE HONORABLE, THE JUDGES OF SAID COURT: -~~ ~° Benjamin J. Cavallazo, Esquire, counsel for the Plaintiff in the above action, respectfully represents that: 1. The above-captioned action is at issue 2. The claim of Plaintiff in the action is $5314.69. The following attorneys aze interested in the case as counsel or are otherwise disqualified to sit as arbitrators: For Defendant For Plaintiff 2 E MAIN STREET Benjamin J. Cavallazo, Esquire SHIREMANSTOWN, PA 17011 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) arbitrators to whom the case shall be submitted. Respec b ' July 28, 2010 B gamin allazo, Esquire ORDER OF COURT AND NOW, , 20_, in consideration of the foregoing petition, and as prayed for. IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA NO.: 10-2036 CIVIL TERM C~ o ~ +t Civil Action - , -~ ,~ c;~.;~ ~ Esq., Esq., are appointed abbitrators in the above captioned action By the Court, ~a~}.oo P p ~~ C~' 19a3g0 {2,'~ ,~4 (o4Sfj /~~E'~~..f--./ Ga iU Q-"~sc" (~°.f11~[l/~/D.U ~a.t~ /t Plaintiff Defendant In The Court of Common Pleas of Cumberland County, PennsylvaniaNo.~- 0?0,~6 Civil Action -Law. Oath We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United States and the Constitution of this Commonwealth and that we will discharge the duties of our office with fidelity. ~ ~~ r Signature - ~~ Name ( airman) s~~~~l ~ ~-P~u[5aJ Law Firm ~~~ Signa e Name -9-~'o--mss ~ ~ ~ /.~,~J. Law Firm /131~%`a -~`!~~ °2 err ~1~.~ p~,,1. Address Address Gj ~' s ~ l1 / ~ l7u 7 C Ty', Zip ~~fi City, Zip ~ ~6?l07 ~ / da d~ e~ ~Z. vf,~s~-, Name r ~,o/ ~G Law Fi ~~3 ~ M~~e~~sf . Address //~~ ~L~ ~< <I U'~ l 701 / City, Zip We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the following award: (Note: If damages for delay are awarded, they sh,~ll be separately stated.) 7~ i~~ a/ro ~~ . Arbitrator, dissents. (Insert name if applicable.) Date of Hearing: - ~ ~ (Chairman) Date of Award: /_h~~o ~~ ~~/~ Notice of En -~, : and __~ - Now, the ~ day of ~~ = "; 28~~, at ' , ' , ~.M., the above award was entered upon the docket and notice thereof given hy. rna41 tv t~t`te parties or their attorneys. ,' Arbitrators' compensation to be paid upon appE~a: ~ ~~~, By: Prothonotary Deputy ~~~~ ~~~,r --Z ~~ ~~ ~~£S M.S.~I£~ ~~ ~ ~~ /!~3 f tC> ~~