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Home My WebLink About12-1922Our File No.: 339188 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. LORIANNE M SWIDLER A/K/A LORI M MUNN 810 DERBY AVE CAMP HILL, PA 17011 Defendant. iL f?fiefF,0AQTP,r ?Jt`fS riLAPdp CCUN 0t' SYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: p1C?I?- l a a CtVt? NnTICF 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 (a) 741 C? 5(-/q P-4-a-? a9sY Our File No.: 339188 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, COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: vs. LORIANNE M SWIDLER A/K/A LORI M MUNN 810 DERBY AVE CAMP HILL, PA 17011 Defendant. 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 LORIANNE M SWIDLER A/K/A LORI M MUNN, an adult individual residing at 810 DERBY AVE 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 1003. 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 $10,441.56. 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 $10,441.56 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & A CIATES, P.C. Attorney r P aintiff A Law Firm Eniza d i Debt Collectiol BY: David J. Apok4ke/,Esquire Dated: 3/14/2012 Our File No.: 339188 VERIFICATION I, David J. Apothaker, Esquire, hereby verify subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities that I am counsel for Plaintiff in this action, that I make this Verification based upon the facts as supplied to me by the Plaintiff and/or its agents and because the Plaintiff is outside the jurisdiction of the court, and that the facts set forth in the foregoing Civil Action Complaint are true and correct to the best of my knowledge, information, and belief. APOTHAKER & S OCIAT , P.C. Attorney or laintif A Law Firm En2a2 d n De Collection BY: David J. Apothaker, DATE: 3/14/2012 AMERICAN EXPRESS CENTURION BANK LORIANNE M SWIDLER A/K/A LORI M MUNN 810 DERBY AVE CAMP HILL, PA 17011 STATEMENT OF ACCOUNT Debtor's Name: LORIANNE M S WIDLER A/K/A LORI M MUNN Account Number: ending in 1003 Balance Due: $10,441.56 Our File No.: 339188 EXHIBIT "A" Our File No.: 339188 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. 2012-1922 CIVIL LORIANNE M SWIDLER A/K/A LORI M MUNN Defendant. PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plaintiff A Law Firm Eniaa ed Debt Collection By: David J. Apothaker, Esquire Dated: 4/5/2012 11111111111111111111111111111 r_ c c r