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Home My WebLink About10-7771Our File No.: 297104 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. 655 PAPERMILL ROAD NEWARK, DE 19711 Plaintiff, vs. JENNIFER L L WARD 8 ROCKWELL CT CARLISLE, PA 17015 Defendant. ~°;~ED-OFFlC ~`~ ?~~~ ~ry~J~s-;~J~1t1-~ 2~10Q~Q 17 P~ 2~ ~Q %U~BE~cLA~~~ CDU~"t `,, 6'EP~NSYL~'A,fl; COURT OF COMMON PLEAS CUMBERLAND COUNTY 7 NO.: 1lJ' 7~~I C/Ul1 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 ~~# 1~5U~ ~~~ asa S ~ ~ Our File No.: 297104 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. 655 PAPERMILL ROAD NEWARK, DE 19711 Plaintiff, vs. JENNIFER L L WARD 8 ROCKWELL CT CARLISLE, PA 17015 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is FIA CARD SERVICES, N.A., 655 PAPERMILL ROAD, NEWARK, DE 1971 1. 2. Defendant(s) is/are JENNIFER L L WARD, an adult individual residing at 8 ROCKWELL CT CARLISLE, PA 17015. 3. At the special instance and request of Defendant, Plaintiff, FIA CARD SERVICES, N.A., issued to Defendant(s), Account # ending in 0416. 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 $2,865.90. 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 $2,865.90 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOC TES, P.C. Attorney for Pl nt A Law Firm Engaged ~4 e t Collection BY: David J. Dated: 12/8/2010 Our File No.: 297104 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. 4~1 relating to unsworn falsification to authorities. David J. App Attorney ker, Esquire Plaintiff DATE: 12/8/2010 FIA CARD SERVICES, N.A. JENNIFER L L WARD 8 ROCKWELL CT CARLISLE, PA 17015 STATEMENT OF ACCOUNT Debtor's Name: JENNIFER L L WARD Account Number: ending in 0416 Balance Due: $2,865.90 Our File No.: 297104 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor F II.EROINBH? A1tY OP THE P ?i 20101}?c ? 9 P ?1 2: CUMBEm- AND C?UP3S Y P?@??S`t?yQN1A FIA Card Services vs. Jennifer L. Ward Case Number 2010-7771 SHERIFF'S RETURN OF SERVICE 12/22/2010 05:22 PM - Ryan Burgett, Deputy Sheriff, who being duly sworn according to law, states that on December 22, 2010 at 1722 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jennifer L. Ward, by making known unto Carol Hely, adult in charge at 8 Rockwell Court Carlisle, Cumberland County, Pennsylvania 17015 its contents and at the same time handing to her personally the said true and correct copy of the same. ?n RYAN BURGET , UTY SHERIFF COST: $33.40 December 27, 2010 SO ANSWERS, RONN"Y ~ R ANDERSON, SHERIFF Our File No.: 297104 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. JENNIFER L L WARD Defendant. FIL.EO-OFFICE OF THE PROTHONOTARY 20111. 1 i 1 ' 9: 31 CUM8E-i-? L.A ;0 U IIJY r., COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-7771 CIVIL PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plaint' A Law Firm Engaged in t ollectioi By: Dated: 12/31/2010 David J. 111111111111111