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Our file No.: 330134
Apothaker & Associates, P.C.
520 Fellowship Road C306
Mount Laurel, NJ 08054
(800) 672-0215
Attorneys for Plaintiff
FIA CARD SERVICES, N.A.
Plaintiff,
VS.
DAVID F BROOKS II
-j T NE PROTNONOTAR't`
2012 FEB 21 PFD 2: 31
"UMBERLAND COUNTY
PENNSYLVANIA
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
DOCKET NO.: 11-8787-CIVIL
Civil Action
'
4
1
STIPULATION IN LIEU OF JUDGMENT
Defendant.
The matters and things in controversy having been discussed by and between the parties,
and a settlement having been agreed upon:
It is on January 03, 2012, STIPULATED by and between FIA CARD SERVICES, N.A.
("Plaintiff') and DAVID F BROOKS II ("Defendant"), as follows:
1. Plaintiff filed suit in the above captioned matter seeking damages in the amount of
$4,373.96, plus court costs in the amount of $825.00, for a total of $5,198.96.
2. Defendant agrees to pay to Plaintiff the sum of $2,475.00; which sum Plaintiff agrees to
accept in full settlement of its claim herein.
3. As of this date, payments totaling $825.00 have been applied to the aforementioned sum.
4. Defendant shall remit payment(s) in the following manner:
a. $825.00 to be paid on or before January 30, 2012 and on or before
February 29, 2012.
5. All checks shall be made payable to "FIA CARD SERVICES, N.A.", and sent to the
office of Plaintiff's attorney, Apothaker & Associates, P.C., located at the following
address:
Apothaker & Associates, P.C.
520 Fellowship Road C306
Mount Laurel, NJ 08054
1
f •
In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation and
the default is not cured within ten (10) days, then Plaintiff shall be entitled to obtain the entry of
Judgment against Defendant in the suit amount, plus court costs, as specified in paragraph one
(1) of this stipulation less any sums paid pursuant to this Stipulation, upon ex parte application,
with supporting certification, and with notice to Defendant in the form of a copy of the
application addressed to Defendant by first-class, postage prepaid.
We hereby consent to the form and entry of the within Stipulation.
By. ----
Be tl?eey Cavallaro, Esquire
ID# 307949
Apothaker & Associates, P.C.
Attorneys for Plaintiff
By: 6j? N?OL? _
DAVID F BROOKS II
Defendant
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Our File No.: 330134
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.
DAVID F BROOKS II
H PRO T HONG iAt"
2012 MAR 26 PH 2: 31:
>UIMBERLAND COUND'
PENNSYLVANIA
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 11-8787-CIVIL
Defendant.
PRAECIPE TO DISMISS WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Kindly dismiss this action without prejudice.
APOTHAKER &
,IATES, P.C.
A Law Firm
By:
David J
Dated: 3/16/2012
Debt Collection
, Esquire