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Home My WebLink About10-2566Our,File No.: 254661 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apdthaker,' 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. DONNA E APGAR 114N21STST CAMP HILL, PA 17011-3808 Defendant. FLED-0t. iuE. 2010 APR ZO AMID: 38 CUM4l`?i'Cr i?LUI?'TY r EEW YLV4,11? COURT OF COMMON PLEAS CUMBERLAND COUNTY ? NO.: 10 - 015(x(, C?v < t- rm 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 C? 4u.oo Pb Airy 04 a4a?79 Our -File No.: 254661 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apo'thaker,'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. DONNA E APGAR 114 N 21ST ST CAMP HILL, PA 17011-3808 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is FIA CARD SERVICES, N.A., 655 PAPERMILL ROAD, NEWARK, DE 19711. 2. Defendant(s) is/are DONNA E APGAR, an adult individual residing at 114 N 21ST ST CAMP HILL, PA 17011-3808. 3. At the special instance and request of Defendant, Plaintiff, FIA CARD SERVICES, N.A., issued to Defendant(s), Account #5490999999524407. 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 $9,824.32. 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 $9,824.32 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER A SOCIATES, Attorn y fo Plaintiff A Law Firm E aRe in Debt 11E Dated: 4/8/2010 BY: David J. Apo f haXer, Esquire Our File No.: 254661 VERIFICATION David J. Apothaker, Esquire, Esc. 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 The undersigned understands that the statements relating to unsworn falsification to authorities. David J. A p( Attorney DATE: 4/8/2010 FIA CARD SERVICES, N.A. DONNA E APGAR 114N21STST CAMP HILL, PA 17011-3808 STATEMENT OF ACCOUNT Debtor's Name: DONNA E APGAR Account Number: 5490999999524407 Balance Due: $9,824.32 Our File No.: 254661 EXHIBIT "A" ` vur F~e No.: 254661 APOTHAKER & ASSOCIATES, P.C. By: Benjamin J. Cavallaro, Esquire Attorney I.D. #307949 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800)672-0215 Attorneys Ybr Plaintiff FIA CARD SERVICES, N.A. 655 PAPERMILL ROAD NEWARK, DE 19711 Plaintiff, vs. DONNA E APGAR 114N21STST CAMP HILL, PA 17011-3808 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 10-2566 CIVIL TERM Civil Action 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 34 S. BEDFORD ST. ~ N :_;i CARLISLE PA 17013 -~ ~~ c.._ -~ 717-249-3166 ~.. r ~ i5r:. .~_ i {~ 7 _ : r ~-- 'T;7 F"l ?-} l _ ~~-_ ~`- ~' ~.-- " ~ ' Our File No.: 254661 APOTHAKER & ASSOCIATES, P.C. By: Benjamin J. Cavallaro, Esquire Attorney I.D. #307949 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. DONNA E APGAR 114N21STST CAMP HILL, PA 17011-3808 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 10-2566 CIVIL TERM AMENDED COMPLAINT FIRST COUNT Civil Action 1. Plaintiff is FIA CARD SERVICES, N.A., 655 PAPERMILL ROAD, NEWARK, DE 19711. 2. Defendant is DONNA E APGAR, an adult individual residing at 114 N 21ST ST CAMP HILL, PA 17011-3 808. 3. Defendant applied for, received and used a credit account issued by FIA CARD SERVICES, N.A., account number 5490999999524407, pursuant to a written agreement in effect at all times relevant herein. 4. Under the terms of the contract, Defendant was given the right to make purchases in return for a promise to timely pay the principal balance accumulated plus interest, fees and penalties where applicable. 5. Defendant failed to make timely payments on the account, although demand was made for said payments, thereby breaching the contract. 6. Defendant opened the account on or about January 1, 1980. 7. Defendant's last payment was recorded on or about March 12, 2009, placing this action within the applicable statute of limitations. 8. The account was charged off on or about October 31, 2009 with an outstanding balance of $9,824.32. 9. Plaintiff has suffered monetary damages in the amount of $9,824.32. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $9,824.32 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney for Plaintiff A Law Firm Engaged in ~gbt Collection BY: Be~fijam~in\~:~'a~Gallaro, Esquire Dated: June 24, 2010 2~4ti(1 f W$7.i~ VERIFICATIQIY ,hereby states that l: am ~LL ~ ~- ~'`'< for Plaintiff, FIA CARD SERVICES,. N.A., in this action, and l am authorized. to make this Verifcation, and that the statements made in the foregoing Civil Action Complaint are true and. correct to the best of my knowledge, information, and belief. The undersigned understands that the statements therein are made subject to the penalties of l 8 Fa.C.S.A.49Q~ relating to unsworn falsification to authorities. Bated: ~ a~ 2b~0 Account hlo.: 5490999999524407 DONNA E APCiAR - ~". .~`"`~ 1CHq a. F j ~.rr~~~~~~~t~~ P ~ I}6 s 1 /~ ~ W « ~~ P U ~$~'¢~~ft FC?Rp.~~~~~~' Our File No.: 254661 APOTHAKER & ASSOCIATES, P.C. By: Benjamin J. Cavallaro, Esquire Attorney I.D. #307949 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 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, vs. DONNA E APGAR 114N21STST CAMP HILL, PA 17011-3808 Defendant. NO.: 10-2566 CIVIL TERM Civil Action CERTIFICATION OF SERVICE I, Benjamin J. Cavallaro, Esquire, attorney for Plaintiff, certify that on June 24, 2010, I mailed a copy of Plaintiff s Amended Complaint by Regular mail to: MICHAEL PYKOSH, ESQUIRE 2132 MARKET ST CAMP HILL, PA 17011 APOTHAKER & ASSOCIATES, P.C. Attorney for Plaintiff A Law Firm Engaged in~t Collection BY: jamin~,T. Cavallaro, Esquire Dated: June 24, 2010 I ~-~ t Our File No.: 254661 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800} 672-0215 Attorney for Plaintiff FIA CARD SERVICES, N.A. Plaintiff, vs. DONNA E APGAR FiLE~ ,E ~ ?~ zf-~L FG - ~ ''~>;Y 2010 Ji.1~ 27 ~'~'1e~ CU~~j ,~,,;,!+Y COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-2566 CIVIL TERM Defendant. PRAECIPE TO DISMISS WITHOUT PREJiJDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & AS TES, P.C. Attorneys fo Pl tiff A Law Firm En~a~ in ebt Collection By: ~.~ David J. Apothaker, Esquire Dated: 7/12/2010