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Home My WebLink About10-7774Our File No.: 297077 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. CONNIE Y WETZEL 37 FOX HILL RD SHIPPENSBURG, PA 17257 Defendant. l: ii-gip-ur ~lC~ ~~{ t ~~~ s'1~~JTi~C~O~'~,~ 1 ~u 10 C!PC 17 P~ 3~ I ~'~r`1~3ERLAt~U CQEI~dT° COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. ~G ~77y NOTICE ~-v~ l 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. p~ CARLISLE PA 17013 ~d ~ ~ 9a ~ ~~ ' "rJ R~'lkkLy 717-249-3166 C ~os~~ Our File No.: 297077 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. CONNIE Y WETZEL 37 FOX HILL RD SHIPPENSBURG, PA 17257 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: ~~~ ~~ ~~ CN- CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is FIA CARD SERVICES, N.A., 655 PAPERMILL ROAD, NEWARK, DE 19711. 2. Defendant(s) is/are CONNIE Y WETZEL, an adult individual residing at 37 FOX HILL RD SHIPPENSBURG, PA 17257. 3. At the special instance and request of Defendant, Plaintiff, FIA CARD SERVICES, N.A., issued to Defendant(s), Account # ending in 6801. 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 $17,734.10. 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 $17,734.10 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & AS CIATES, P.C. Attorney r aintiff A Law Firm End ed ' Debt C ectio~ BY: Dated: 12/8/2010 David J. A~o~fiaker, Esquire Our File No.: 297077 VERIFICATION David J. Apothaker, Esquire, Esg, 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 beef. 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. David J. Apothaker, Esquire Attorney for Plaintiff DATE: 12/8/2010 FIA CARD SERVICES, N.A. CONNIE Y WETZEL 37 FOX HILL RD SHIPPENSBURG, PA 17257 STATEMENT OF ACCOUNT Debtor's Name: CONNIE Y WETZEL Account Number: ending in 6801 Balance Due: $17,734.10 Our File No.: 297077 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff iL 0-0 FIC, Jody S Smith Chief Deputy tJj I -JA?? _' PM 12; it s Richard W Stewart Solicitor 0UMBERLAKD COU111 'li' FIA Card Services I Case Number vs. 2010-7774 Connie Y. Wetzel SHERIFF'S RETURN OF SERVICE 12/2912010 06:25 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on December 29, 2010 at 1825 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Connie Y. Wetzel, by making known unto herself personally, at 37 Fox Hill Road, Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $46.00 January 04, 2011 RO ERT BITNER, PUTY SO ANSWERS, f? RON R ANDERSON, SHERIFF FILED-OFFICE Tracy L. Updike, Esquire o F rHE P RO T HON 0 TAR`t' PA Supreme Court ID # 88680 2011 FEB -2 PM 12: 54 CUNNINGHAM & CHERNICOFF, P.C. 2320 North Second Street CUMBERLAND CQUNT'-' P.O. Box 60457 PENNSYLVANIA Harrisburg, PA 17106-0457 (717) 238-6570 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIA CARD SERVICES N.A., Plaintiff, vs. CONNIE Y. WETZEL, Defendant CIVIL ACTION - LAW No. 10-7774 NOTICE OF STAY NOTICE IS HEREBY GIVEN that Connie Y. Wetzel, above-named Defendant, has filed a Petition under Chapter 13 of the United States Bankruptcy Code to Case No. 1-11-00572 and as a result thereof, the above-captioned action is stayed until further Order of the United States Bankruptcy Court. The undersigned executes this Notice for purposes of giving notice only; and the providing of this Notice is not intended to enter an appearance in the within case. Respectfully submitted, Date: January 31, 2011 CUNNINGHAM & CHERNICOFF, P.C. By: I Tra L. Upd' , Esquire I.D. #88680 2320 North Second Street P.O. Box 60457 Harrisburg, PA 17106-0457 (717) 238-6570 Tracy L. Updike, Esquire PA Supreme Court ID # 88680 CUNNINGHAM & CHERNICOFF, P.C. 2320 North Second Street P.O. Box 60457 Harrisburg, PA 17106-0457 (717) 238-6570 IN THE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY, PENNSYLVANIA FIA CARD SERVICES N.A., CIVIL ACTION - LAW Plaintiff, No. 10-7774 vs. CONNIE Y. WETZEL, Defendant CERTIFICATE OF SERVICE I, Lisa Fuge, do hereby certify that a true and correct copy of the NOTICE OF STAY was sent by first class mail, postage prepaid on this day to the following: David J. Apothaker, Esquire 520 Fellowship Road C306 Mount Laurel, NJ 08054 Date: January 31, 2011 F: \Home\LFUGE\ W ETZEL-CONNIE\NOTICEBK-FIA.wpd Respectfully submitted, CUNNINGHAM & CHERNICOFF, P.C. By: Lisa Fuge, Parale 1 2 40- FILED-OF Its 11, L Our File No.: 297077 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. CONNIE Y WETZEL Defendant. 2011 FEB 18 P 1?::? !-! p f7 `'s COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 10-7774 CIVIL PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys foMnD iff A Law Firm Engaged t Collection By: David J. Avothak • Esquire Dated: 2/9/2011 I?IIIIIIII?IIII?