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Home My WebLink About10-7531Our File No.: 295533 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney LD. #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. BENJAMIN DRAPER 6260 RUN CROSS LN ENOLA, PA 17025 Defendant. ~~ rN~ ~oT~or~€o~-~~~~., ZO f 0 qEC - 6 p~ 3: O f ~'UMB~RLAf~O C(lU~~iTi' PENt~;Y~V~;1dfA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. ~ ~ ~~ J~~ 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 ~v a~ ~~,~,~ °° ~ ~;5~ i Our File No.: 295533 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. BENJAMIN DRAPER 6260 RUN CROSS LN ENOLA, PA 17025 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY j NO.: IQ ~ ~j ~ 3 ~ G1il~ ~ ~~l~w f /' 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 BENJAMIN DRAPER, an adult individual residing at 6260 RUN CROSS LN ENOLA, PA 17025. 3. At the special instance and request of Defendant, Plaintiff, AMERICAN EXPRESS CENTURION BANK, issued to Defendant(s), Account # ending in 1008. 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 $18,690.53. 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 $18,690.53 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & A~CIATES, P.C. Attorney A Law Firm Engag BY: David J. And Debt Esquire Dated: 11 /24/2010 Our File No.: 295533 VERIFICATION David J. Anothaker Esquire Esp 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 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. Apothaker, Esquire Attorney for Plaintiff DATE: 11 /24/2010 ~, AMERICAN EXPRESS CENTURION BANK BENJAMIN DRAPER 6260 RUN CROSS LN ENOLA, PA 17025 STATEMENT OF ACCOUNT Debtor's Name: BENJAMIN DRAPER Account Number: ending in 1008 Balance Due: $18,690.53 Our File No.: 295533 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor American Express Centurion Bank vs. Benjamin Draper ?010 DEC 21 PM '3: C 35 r-,U MBERLAND vC;Ui° T PENH$YLVAMI Case Number 2010-7531 SHERIFF'S RETURN OF SERVICE 12/13/2010 06:45 PM - Stephen Bender, Deputy Sheriff, who being duly sworn according to law, states that on December 13, 2010 at 1845 hours, he served a tr e copy of the within Complaint and Notice, upon the within named defendant, to wit: Benjamin Draper,',by making known unto himself personally, at 6260 Run Cross Lane, Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to him personally the said true and correct copy of the same. ygz- ez STEPHEN BENDER, DEPUTY SHERIFF COST: $41.50 December 15, 2010 SO ANSWERS, wy 2 RON R ANDERSON, SHERIFF IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA, CIVIL DIVISION AMERICAN EXPRESS CENTURION BANK V. BENJAMIN DRAPER DOCKET NO.: 10-7.& 7 PRAECIPE TO ENTER APPEARANCE TO: PROTHONOTARY Please enter my appearance on behalf of the Defendant, Benjamin referenced matter. Date: Respectfully Submitted, Rominger & Associates Karl ominger, Esquire 15 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Defendant n the above > -? rn -< N N '0 ZC? n -f 'Z2 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY PENNSYLVANIA, CIVIL DIVISION AMERICAN EXPRESS CENTURION BANK DOCKET NO.: 10-7,?31 V. BENJAMIN DRAPER CERTIFICATE OF SERVICE I, Karl E. Rominger, Esquire, certify that I this day served a copy of the within Praecipe to Enter Appearance upon the following by depositing the same in the United States Mail, postage pre-paid, via first class mail, in Carlisle, Pennsylvania, addressed as follows: David J. Apothaker, Esquire 520 Fellowship Road C306 Mount Laurel, NJ 08054 Respectfully Submitted, Rominger & Associates Date: Karl . ominger, Esquire 155 South Hanover Street Carlisle, Pennsylvania 17013 (717) 241-6070 Supreme Court ID # 81924 Attorney for Defendant Our File No.: 295533 C.1?' T HE PAR THE iC T./,i ; y APOTHAKER & ASSOCIATES, P.C.?? BY: David J. Apothaker Esquire DEC 2$ (,: 44 Attorney I.D.# 38423 "U PE ERLAND C Lit,' -y 520 Fellowship Road C306 Mount Laurel, NJ 08054' `' (800) 672-0215 Attorney for Plaintiff AMERICAN EXPRESS CENTURION BANK Plaintiff, VS. BENJAMIN DRAPER Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-7531 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. A Law Firm EngaAed ii Debt By: L/ David J. Apoth r, Esquire Dated: 12/15/2010