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Home My WebLink About10-5739Our File Rio.: 287984 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 AMERICAN EXPRESS CENTURION BANK 4315 S 2700 WEST SALT LAKE CITY, UT 84184 Plaintiff, VS. RICHARD PARSONS 2232 CANTERBURY DR MECHANICSBURG, PA 17055 Defendant. kRy COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: to - 6739 cw it t em 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. CARLISLE PA 17013 717-249-3166 O +qA-00 Po" 0 M545 0,22-14'7713 IL Our File No.: 287984 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 AMERICAN EXPRESS CENTURION BANK 4315 S 2700 WEST SALT LAKE CITY, UT 84184 Plaintiff, VS. RICHARD PARSONS 2232 CANTERBURY DR MECHANICSBURG, PA 17055 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT I. Plaintiff is AMERICAN EXPRESS CENTURION BANK, 4315 S 2700 WEST, SALT LAKE CITY, UT 84184. 2. Defendant(s) is/are RICHARD PARSONS, an adult individual residing at 2232 CANTERBURY DR MECHANICSBURG, PA 17055. 3. At the special instance and request of Defendant, Plaintiff, AMERICAN EXPRESS CENTURION BANK, issued to Defendant(s), Account # ending in 2003. 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 $9,089.97. 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 $9,089.97 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSO -YATES, P.C. Attorney for P ai tiff A Law Firm Engaged ebt Coll iol BY: David J. ApothAer, Esquire Dated: 8/26/2010 Our File No.: 287984 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, and belief. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 qeting to unworn falsification to authorities. David J. Apothaar Esquire Attorney for Plaintiff DATE: 8/26/2010 1 AMERICAN EXPRESS CENTURION BANK RICHARD PARSONS 2232 CANTERBURY DR MECHANICSBURG, PA 17055 STATEMENT OF ACCOUNT Debtor's Name: RICHARD PARSONS Account Number: ending in 2003 Balance Due: $9,089.97 Our File No.: 287984 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith ` Chief Deputy Richard W Stewart Solicitor American Express Centurion Bank Case Number vs. Richard Parsons ?010-5739 SHERIFF'S RETURN OF SERVICE 09/14/2010 02:35 PM - Michael Barrick, Deputy Sheriff, who being duly sworn according to law, states that on September 14, 2010 at 1435 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Richard Parsons, by making known unto Michelle Parsons, Wife of defendant at 2232 Canterbury Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true an? c ct copy of the same. MICHAEL BARRICK, DEPUTY SHERIFF COST: $37.00 September 15, 2010 SO ANSWERS, RON R ANDERSON, SHERIFF T ldr 01% r- _ 0 c..: M _13 ~~/1 ~~C~,~ ~i~,Q~~S Cv~irllr/~~a~..~ 6~~ 4ais`'s, ~7oa ~w~-s T ~s ~~i,~~i,~ ~'~8~ z23z ~,~tr~~v~~' ~~ ~nv~ p~~o~~r~ Pt~~ ~~~~~,~ c~~~y D3JEC ~ io,~l ~ c ~ ~~ ~ 3 0 ~ ~ ~ ~~ c np ~o ~ ~ ~ ~° ~ ~ -~ :~ ~~ ~~ .~ /eG~eiU~ed 4 /PffG+~o~[ S~Pp~rnben J¢, ~niD no~~:Ks s4i~e ~`~t~ ~/+e law ~%'rn~, ~ ,~00~/~ert.rl5sDliaf85~ 9~, ~~ Q P4,Q~ (~i/e #~~g$9-~ S~d~h~ s~lia~ we were ~.~ o~ul~ m~a ou r •9~ericaM 6xp~-~sS GCcov~f. t~t/e O.G,Jec~,~~J,~a~ chao~e, Ul/ ~zy ev~v-l n~otirf;~ b u¢ d~a' ~ %ss a f~ty~~x,~ %n tila y h~caus~o-~~~~iyk~b~~~r~d~ t.~-,~y~~E ~~-~-~ ~Dl~OU1Tn ~D M~1~i3. Te~~ tie Dc~Q5~dx5 a/~e~n ~O~'Yr~~~ wtio /af~ o~S~ bzca,~,cs~ ~;~ ~~i rrr~~~o1~{~ ~n~f ,y ~l ~a~ dal dlol n-of aG~~.. N/e 6el~rv~ fourgecou~ 5hau.ld nod ~a~'~ been p~ ire ale~eu-~l-~-ao+d ~ha~~ki's a~ ~e rr`a ~~ ~cy~.o aids FILED-OFFICE OF THE PROTHONOTARY Our File No.: 287984 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 2011 J': ; 3 1 CUMQcL' ' u NTY r7!s+?`. _i?. - i?-_.?.?.1A AMERICAN EXPRESS CENTURION BANK COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, VS. NO. 10-5739 CIVILTERM RICHARD PARSONS Defendant. PRAECIPE TO SUBSTITUTE VERIFICATION TO THE PROTHONOTARY: Please substitute the attached Verification in place of the Attorney's Verification on the Complaint filed on September 9, 2010. APOTHAKE(eys A)SSOCIATES, P.C. Atto r Plaintiff A Law Firm d in Debt Collectior By: David J. Apothaker, Esquire Dated: January 10, 2011 Our File No.: 287984 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 AMERICAN EXPRESS CENTURION BANK COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff VS. RICHARD PARSONS Defendant CERTIFICATION OF SERVICE Civil Action I, David J. Apothaker, Esquire, attorney for Plaintiff, certify that on January 10, 2011, I mailed a copy of Plaintiff's Praecipe to Substitute Verification to: Richard Parsons 2232 Canterbury Dr Mechanicsburg, Pa 17055 APOTHAKER & Attorney A Law Firm Enjza4 BY: David J. A CIATES, P.C. iii Debt Esquire NO.: 10-5739 CIVILTERM Dated: January 10, 2011 GWENETTE MOSER VERIFICATION ASSISTANT CUSTODIAN OF RECORDS ICJ ?- , hereby states that I am for Plaintiff, AMERICAN EXPRESS CENTURION BANK, in this action, and I am authorized to make 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 relating to unsworn falsification to authorities. Dated: GWENETTE MOSER STOOD Account No.: 3732-108165-02003 OSRTOAONRT" RICHARD PARSONS OCT 12 2oio -J L B Our File'No.: 287984 AMERICAN EXPRESS CENTURION BANK Plaintiff vs. RICHARD PARSONS Defendant IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVAW c C ,,..a NO.: 10-5739 CIVILTERM ?rn e =-I M -- Civil Action w ? r --ta zc? z-n z a: r °'rn PRAECIPE FOR APPOINTMENT OF ARBITRATORS n TO THE HONORABLE, THE JUDGES OF SAID COURT: Kimberly F. Scian, 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 $9089.97. The following attorneys are interested in the case as counsel or are otherwise disqualified to sit as arbitrators: For Defendant For Plaintiff Kimberly F. Scian, Esquire 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. June 22, 2011 AND NOW, and as prayed for. R spectfull ubmitted, r K' rly F. Scian, Esquire ORDER OF COURT Esq., and Esq., Esq., are appointed arbitrators in the above captioned action &rVA qay, to eJ °l? CLW Wbtl 20_, in consideration of the foregoing petition, By the Court, Our File'No.: 287984 AMERICAN EXPRESS CENTURION BANK ) Plaintiff ) vs. ) RICHARD PARSONS ) Defendant ) IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSY - LVAW C ) o _ NO.: 10-5739 CIVILTERM - r -gym Civil Action wcn r ZCo z c? v,z '. ern PRAECIPE FOR APPOINTMENT OF ARBITRATORS --{ -- ? rn TO THE HONORABLE, THE JUDGES OF SAID COURT: Kimberly F. Scian, 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 $9089.97. The following attorneys are interested in the case as counsel or are otherwise disqualified to sit as arbitrators: For Defendant For Plaintiff Kimberly F. Scian, Esquire 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. June 22, 2011 R s;rly tfull ubmitted, K' F. Scian, Esquire C? to L"l ORDER OF COURT AND NOW, 20/1 , in consideration of the foregoing petition, -4 1 1j, .1 Esq., and Esq., and Esq., are appointed arbitrators in the above captioned action as prayed for. VINVAIASNN3d B j, i .gnco 0NV1838Wf13 y the Court, A 11:9 WV Z I Zfir 1101 (gip; Ps ?'+ac. 1 ?? 7 ? f ? ?l r ? L David q). Buell - Prothonotary Office of the Prothonotary Cum6erfand County, cPennsyfvania 7�yr&S. Sohonage, T SQ Solicitor 16—S737 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28T" DAY OF OCTOBER, 2014, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE —THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P.230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY One Courthouse Square 0 Suite100 0 CarCisCe, TA 0 (Phone 717 240-6195 0 'Fax 717 240-6573