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Home My WebLink About11-0481i , . Our File No.: 305376 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. RANDY FULTZ 1112 SHANNON LN CARLISLE, PA 17013 Defendant. FILED-OFFICE S COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: I I - y81 (21V i I Tt°r lh 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 (05) +gQ1.OO P?4 Arr4 0"141 I 0453ga3 Our File No.: 305376 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 CEN 1 URION BANK 4315 S 2700 WEST SALT LAKE CITY, UT 84184 Plaintiff, vs. RANDY FULTZ 1112 SHANNON IN CARLISLE, PA 17013 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 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 RANDY FULTZ, an adult individual residing at 1112 SHANNON LN CARLISLE, PA 17013. 3. At the special instance and request of Defendant, Plaintiff, AMERICAN EXPRESS CENTURION BANK, issued to Defendant(s), Account # ending in 1007. 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 $12,475.78. 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 $12,475.78 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & AX SOCIATES, P.C. Attorney; fo Plaintiff A Law Firm Enaake in Debt?Collectioi BY: David J. ApTtthaker, Esquire Dated: 1/11/2011 Our File No.: 305376 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. 4904 relating to unworn falsification to authorities. E David J. Apothaker, Esquire Attorney for Plaintiff DATE: 1/11/2011 AMERICAN EXPRESS CENTURION BANK RANDY FULTZ 1112 SHANNON LN CARLISLE, PA 17013 STATEMENT OF ACCOUNT Debtor's Name: RANDY FULTZ Account Number: ending in 1007 Balance Due: $12,475.78 Our File No.: 305376 EXHIBIT "A" 305376 Request for Service R. Thomas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.6390 Fx: 717-240-6397 Plaintiff/s: Court Number: AMERICAN EXPRESS CENTURION Expiration Date: BANK Type of Action: Civil Action Defendant/s: RANDY FULTZ Serve Upon: RANDY FULTZ Address for Service: 1112 SHANNON LN CARLISLE, PA 17013 Alternate Address for Service: Type of Service: ( ) Personal (X) Adult in Charge () Deputize () Certified Mail () Posting Special Service Instructions: * * If service is to be made by deputized service to another county please specify which county Filing Attorney Information: Name: Apothaker & Associates, P.C. Address: 520 Fellowship Road C306 Mount Laurel, NJ 08054 Telephone: 215-634-8920 V Our File No.: 305376 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 AMERICAN EXPRESS CENTURION BANK COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, VS. NO. 11-481-CIVILTERM RANDY FULTZ Defendant. PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & AQ1 AttornFee A Law Firm En By: D avid J Dated: 4/28/2011 1111111111111111111 TES, P.C. Debt Collection ,'Esquire :-? C= W M rn? o° Drl