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Home My WebLink About11-4229Our File No.: 316735 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, UTAH 84148 Plaintiff, vs. PETER BOLTON 483 COUNTRY CLUB RD CAMP HILL, PA 17011 Defendant. FILED )FF11-E: I HE f` t 0 !?1? r Lu11 M -9 P1112:05, CUMBERLAND COUN'-",' a?EljrCOURT OF COMMON PLEAS CUMBERLAND/ COUNTY NO.: / - ',? l ??V I 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 Pd(- 11?wx 4wy G?,?s# aG 337 ,PL?o1S" 7 Our File No.: 316735 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, UTAH 84148 Plaintiff, vs. PETER BOLTON 483 COUNTRY CLUB RD CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is American Express Centurion Bank ("Plaintiff'), a state chartered industrial loan bank chartered in the state of Utah with a principal place of business in Salt Lake City, Utah. 2. Defendant(s) is/are PETER BOLTON, an adult individual residing at 483 COUNTRY CLUB RD CAMP HILL, PA 17011. 3. At the special instance and request of Defendant, Plaintiff, AMERICAN EXPRESS CENTURION BANK, issued to Defendant(s), Account # ending in 2004. 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 $29,148.32. 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 $29,148.32 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney for Plaintiff A Law Firm EngawA in Debt Collection BY: David J. AAth4Ver, Esquire Dated: 5/4/2011 Our File No.: 316735 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 unsworn falsification to authorities. David J. Apotha Attorney for DATE: 5/4/2011 AMERICAN EXPRESS CENTURION BANK PETER BOLTON 483 COUNTRY CLUB RD CAMP HILL, PA 17011 STATEMENT OF ACCOUNT Debtor's Name: PETER BOLTON Account Number: ending in 2004 Balance Due: $29,148.32 Our File No.: 316735 EXHIBIT "A" 316735 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 Plaintiffs: Court Number: AMERICAN EXPRESS CENTURION Expiration Date: BANK Type of Action: Civil Action Defendant/s: PETER BOLTON Serve Upon: PETER BOLTON Address for Service: 483 COUNTRY CLUB RD CAMP HILL, PA 17011 Alternate Address for Service: Type of Service: ( ) Personal (X) Adult in Charge O Deputize O Certified Mail O 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 Our File No.: 316735 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 F ILED-O%CE GF THE PROTN NOTARY 2011 JUL 18 PM 2: 31 CUMBERLAND COUNTY PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, vs. NO. 11-4229-CV PETER BOLTON Defendant. PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys for Tebt iniff A Law Firm Engage in Coll50on ( tz By: David J. Apothaker, Esquire Dated: 7/7/2011 ?IIOI1?Iw111IN1