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Home My WebLink About10-2841• ,Our File No.: 253767 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 CHASE BANK USA, N.A. 3700 WISEMAN BLVD BLDG 2 1 ST FLOOR SAN ANTONIO, TX 78251 Plaintiff, VS. MICHAEL D FAUST 4 ROCKLEDGE CT CARLISLE, PA 17015-9190 Defendant. 4 i l rr ryY THE 2010 APR 28 Pil I : L, 8 CUA, ' .!rVfY { A Pp feet F+?ti.l; ?Ii/'1 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 10 - aS41 NOTICE 0, i V i t -1 enu 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 Ci) 49a. oo Pa Art ftt ma15 e ayIa7I ,Our File No.: 253767 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 CHASE BANK USA, N.A. 3700 WISEMAN BLVD BLDG 2 1ST FLOOR SAN ANTONIO, TX 78251 Plaintiff, VS. MICHAEL D FAUST 4 ROCKLEDGE CT CARLISLE, PA 17015-9190 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is CHASE BANK USA, N.A., 3700 WISEMAN BLVD BLDG 2 1 ST FLOOR, SAN ANTONIO, TX 78251. 2. Defendant(s) is/are MICHAEL D FAUST, an adult individual residing at 4 ROCKLEDGE CT CARLISLE, PA 17015-9190. 3. At the special instance and request of Defendant, Plaintiff, CHASE BANK USA, N.A., issued to Defendant(s), Account #4266902018935799. 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 $8,994.50. 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. v - WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $8,994.50 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIAT , P.C. Attorney for Plainti A Law Firm Engaged in D t ollectioi BY: David J. Dated: 4/21/2010 Our File No.: 253767 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. 4994/relating to unsworn falsification to authorities. David J. Apothaker, Esquire Attorney for Plaintiff DATE: 4/21/20 10 CHASE BANK USA, N.A. MICHAEL D FAUST 4 ROCKLEDGE CT CARLISLE, PA 17015-9190 STATEMENT OF ACCOUNT Debtor's Name: MICHAEL D FAUST Account Number: 4266902018935799 Balance Due: $8,994.50 Our File No.: 253767 EXHIBIT "A" .. a w Our file No.: 253767 ~Z APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff Attorney ID# 307949 I~ JU"~~ 2 ~ 2010 } CHASE BANK USA, N.A. ) Plaintiff, ) vs. ) MICHAEL D FAUST ) Defendant. ) ~.- ~l~Ci f r~..~" ~j k ~- 7~"f ~ L r r~ ~~`~~~~ 201QJ~JL -I A~fli~ I3 CGE~,~~~ ~;, ~ sJ,,~;~;r~.,~, <~ ~'~~'t~~vY~.V~V IFS ' r COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 10-2841 CIVIL TERM Civil Action STIPULATION 1N LIEU OF JUDGMENT The matters and things in controversy having been discussed by and between the parties, and a settlement having been agreed upon: It is on June 11, 2010, STIPULATED by and between Plaintiff, CHASE BANK USA, N.A., and Defendant, MICHAEL D FAUST parties as follows: 1. Defendant agrees to pay the sum of $9,119.90, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. The sum aforesaid of $9,119.90 shall be paid by the by Defendant, MICHAEL D FAUST, to the attorneys for Plaintiff in the following manner: a. $2,500.00 to be paid on or before June 28, 2010; b. $1,225.00 to be paid on or before the 28~' day of each month, beginning July 28, 2010 through August 28, 2010. All checks aze to made payable to CHASE BANK USA, N.A., and sent to: Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 3. In the event Defendant, MICHAEL D FAUST makes all payments as stated above, this account will mazked satisfied when MICHAEL D FAUST pays $4,950.00. J- r 4. In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation, then, and in that event, Plaintiff shall be entitled to obtain the entry of Judgment against Defendant ex parte, in the sum of $9,119.90, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. 5. In the event of default as aforesaid, Plaintiff shall be entitled to obtain the entry of Judgment upon ex parte application, with supporting certification, and with notice to Defendant only in the form of a copy of the application addressed to MICHAEL D FAUST by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plain ~' A Law Firm Engaged in I~t~Collection sy: J. Cavallaro, Esquire MICHAEL D FAUST Our File No.: 253767 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 CHASE BANK USA, N.A. Plaintiff, vs. MICHAEL D FAUST Defendant. ii_~~-0~~~= ICS 2t~ l0 OCT - i P~~ Z~ ~ ~ ~l1~iBERI-~~~D ~0~1~dT~' ~'~~~S~'~.'~~t~lA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-2841 CIVIL TERM PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys for laintiff A Law Firm En~a~Debt Collection By: Dated: 9/22!2010 David J. Ap ler, Esquire 111~1~111111111