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HomeMy WebLinkAbout10-7079Our File No.: 287469 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. 4161 PIEDMONT PKWY GREENSBORO, NC 27410-8110 Plaintiff, VS. DARRYLJRYAN 110 FAIRWAY DR CARLISLE, PA 17015-9365 Defendant. ,- k a g COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. it - '7bq] Vil-1Prm I 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 0 Ra. oo P q ?? 34oq (?, d50 9,30 Our File No.: 287469 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. 4161 PIEDMONT PKWY GREENSBORO, NC 27410-8110 COURT OF COMMON PLEAS CUMBERLAND COUNTY 'I NO.: Plaintiff, VS. DARRYLJRYAN 110 FAIRWAY DR CARLISLE, PA 17015-9365 Defendant. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is FIA CARD SERVICES, N.A., 4161 PIEDMONT PKWY, GREENSBORO, NC 27410-8110. 2. Defendant(s) is/are DARRYL J RYAN, an adult individual residing at 110 FAIRWAY DR CARLISLE, PA 17015-9365. 3. At the special instance and request of Defendant, Plaintiff, FIA CARD SERVICES, N.A., issued to Defendant(s), Account # ending in 8058. 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 $39,019.89. 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 $39,019.89 and requests this Court award costs to the extent permitted by applicable law. /11 APOTHAKER/& ASOCIATES, P.C. .., € I1 r, . . - A Law Firm Engaged in Delft Collection BY: David J. Ahothaker, Esquire Dated: 10/20/2010 Our File No.: 287469 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. 494 relating to unworn falsification to authorities. David J. Ap aker, Esquire Attorney for Plaintiff DATE: 10/20/2010 FIA CARD SERVICES, N.A. DARRYLJRYAN 110 FAIRWAY DR CARLISLE, PA 17015-9365 STATEMENT OF ACCOUNT Debtor's Name: Account Number: Balance Due: Our File No.: 287469 DARRYLJRYAN ending in 8058 $39,019.89 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson C-) C © C) Sheriff 0111tr of Claut#irrf r a) r Z Jody S Smith 4, y n ?rn "-' ° o rn- Chief Deputy _ r- r ?o C:) Richard W Stewart ' ra v o Solicitor ?'F"C ;^ R ? tsE'H MFF o -n .=p = y.C z N C)rn FIA Card Services C N be vs. Darryl J. Ryan now um r 2010-7079 SHERIFF'S RETURN OF SERVICE 11/17/2010 08:48 PM - Ronald Hoover, Deputy Sheriff, who being duly sworn according to law, states that on November 17, 2010 at 2048 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Darryl J. Ryan, by making known unto Victoria Ryan, Wife of defendant at 110 Fairway Drive, Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $33.40 November 18, 2010 Z- ey RONALD HOOVER, DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF fc) GountySuite Sheriff. Teleosoft. Inc. David BueCI Prothonotary Office of the Prothonotary Cum6er[and County, Tennsyfvania r&S. Sofionage, E,SQ Solicitor — #Q 79 CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 28TH 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 • Suite100 • Carlile, PA 0 (Phone 717 240-6195 • TaK 717 240-6573