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Home My WebLink About11-4912Our File No.: 318567 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. CHANASCHOENBERG 4109 MTN VIEW RD MECHANICSBURG, PA 17050 Defendant. f t ICE f Y JE e;'i f7 7! erlf:e ? 201 r JUN, 13 PM 12: U 1J'%1ERL,4 PENNSYLVANI/A COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 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 9a -oo Pet . Our File No.: 318567 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 COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, vs. CHANASCHOENBERG 4109 MTN VIEW RD MECHANICSBURG, PA 17050 Defendant. 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 CHANA SCHOENBERG, an adult individual residing at 4109 MTN VIEW RD MECHANICSBURG, PA 17050. 3. At the special instance and request of Defendant, Plaintiff, AMERICAN EXPRESS CENTURION BANK, issued to Defendant(s), Account # ending in 1004. 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 $11,228.40. 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 $11,228.40 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASS IATES, P.C. Attorney fo 1 ntiff A Law Firm Engag d in ebt Collection BY: David J. ApktLker, Esquire Dated: 6/6/2011 Our File No.: 318567 VERIFICATION David J. Apothaker. Esquire 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 relati to nsworn falsification to authorities. David J. Apothaker, Esquire Attorney for Plaintiff DATE: 6/6/2011 AMERICAN EXPRESS CENTURION BANK CHANASCHOENBERG 4109 MTN VIEW RD MECHANICSBURG, PA 17050 STATEMENT OF ACCOUNT Debtor's Name: CHANA SCHOENBERG Account Number: ending in 1004 Balance Due: $11,228.40 Our File No.: 318567 EXHIBIT "A" 318567 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: CHANASCHOENBERG Serve Upon: CHANASCHOENBERG Address for Service: 4109 MTN VIEW RD MECHANICSBURG, PA 17050 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 SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Z Sheriff ul 4t t?,ru,brry ?ia? r -o ff Jody S Smith ?re <:t, N e?? ,. ' Chief Deputy Richard W Stewart ° Solicitor American Express Centurion Bank Case Number vs. 2011-4912 Chana Schoenberg SHERIFF'S RETURN OF SERVICE 06/16/2011 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Chana Schoenberg, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Chana Schoenberg. Deputies were advised by the Defendant's sister in law, Chana Schoenberg has moved out of the country. SHERIFF COST: $43.00 SO ANSWERS, June 17, 2011 RON R ANDERSON, SHERIFF c Goun+ySuitn Snet tt. 7eleo oft. Inr,. r Our File No.: 318567 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 Plaintiff, vs. CHANA SCHOENBERG Defendant. FILED'OFFICE 01 THE PR0THON0Tt?r r' 2011 JUL 22 PM 2= 09 kCUMSERL,AND COUN F PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 11-4912-CV PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys ndi Iaintiff A Law Firm Enaa Debt Collection By: David J. Ap al , Esquire Dated: 7/18/2011 111111111111111111111111111111111