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Home My WebLink About11-3495Our File No.: 305821 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. DIMITRIA D ADKINS 1481 ENGLISH DR MECHANICSBURG, PA 17055 Defendant. Vi Fi0E 2011 APIR -6 AM 10: 1 UMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 11- aye S NVO 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 '2 cod a t?a335s 95`7531 i ' Our File No.: 305821 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. DIMITRIA D ADKINS 1481 ENGLISH DR MECHANICSBURG, PA 17055 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is FIA CARD SERVICES, N.A., 655 PAPERMILL ROAD, NEWARK, DE 19711. 2. Defendant(s) is/are DIMITRIA D ADKINS, an adult individual residing at 1481 ENGLISH DR MECHANICSBURG, PA 17055. 3. At the special instance and request of Defendant, Plaintiff, FIA CARD SERVICES, N.A., issued to Defendant(s) a credit account. 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 $12,158.27. 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 i ' WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $12,158.27 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER S OCIATES, P.C. Atto y fo Plaintiff A Law Firm E aaae in Debt Collection BY: David J. A , Esquire Dated: 4/1/2011 Our File No.: 305821 • 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 b ie£ The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A, 49 relating to unsworn falsification to authorities. I E J` David J. Apot aker, Esquire Attorney for Plaintiff DATE: 4/1/2011 FIA CARD SERVICES, N.A. DIMITRIA D ADKINS 1481 ENGLISH DR MECHANICSBURG, PA 17055 STATEMENT OF ACCOUNT Debtor's Name: DIMITRIA D ADKINS Account Number: ending in 3791 Balance Due: $12,158.27 Our File No.: 305821 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff OF,- ,E`.Th ?kP;F OF T H OTfj ;,,) R , Jody S Smith Chief Deputy Richard W Stewart Solicitor X11 IPR / / Pfd 12: t;8 CUMBERLAND C Y PENNSYLVANtgN? . FIA Card Services vs. Dimitria D. Adkins Case Number 2011-3495 SHERIFF'S RETURN OF SERVICE 04/07/2011 09:20 PM - Timothy Black, Deputy Sheriff, who being duly sworn according to law, states that on April 7, 2011 at 2120 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Dimitria D. Adkins, by making known unto herself personally, at 1481 English Drive, Mechanicsburg, Cumberland County, Pennsylvania 17055 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $38.00 April 08, 2011 TIM B C , DEPUTY SO ANSWERS, RON R ANDERSON, SHERIFF fC CountySuite Sheriff. T'etecsoff. Inc.