The URL can be used to link to this page

Home My WebLink About14-6961 Supfeme Court f Pennsylvania _ Courfof Common Pleas at-,INil.Co�-e , Beet For Prothonotary Use Only: C-1A1-ERL�AND Docket Iva: Countti' �f The information collected on this forin is used s0le41 for Corin administration purposes. This form does not supplement or replace the filing and service of pleadings or other papers as required by 1mv or rules of court. S Commencement of Action: E ® Complaint El Writ of Summons El Petition ❑ Transfer from Another Jurisdiction ❑ Declaration of Taking C Lead Plaintiffs Name: Lead Defendant's Name: G T BARCLAYS BANK DELAWARE JOSEPH H GERDES j I Are money damages requested? ® Yes ❑ No Dollar Amount Requested: ® within arbitration limits Q (check one) ❑ outside arbitration limits N Is this a Class Action Suit? ❑ Yes N No Is this an MDJAppeal? ❑ Yes ® No A Name of Plaintiff/Appellant's Attorney: Apothaker Scian P.C. l _ ❑ Check here if you have no attorney(are a Self-Represented [Pro Se] Litigant) I Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE.If you are making more than one type of claim, check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT (do not include Judgments) CIVIL APPEALS ❑ Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ® Debt Collection:Credit Card ❑ Board of Assessment ❑ Motor Vehicle ❑ Debt Collection: Other ❑ Board of Elections ❑ Nuisance ❑ Dept.of Transportation ❑ Premises Liability ❑ Statutory Appeal:Other S El include Liability(does not ❑ I include mass tort) Employment Dispute: E [:1Slander/Libel/Defamation Discrimination ❑ Other: ❑ Employment Dispute: Other C ❑ Zoning Board T ❑ Other: I ❑ Other: O MASS TORT ❑ Asbestos N ❑ Tobacco ❑ Toxic Tort-DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort-Implant ❑ Ejectment ❑ Common Law/Statutory Arbitration ❑ Toxic Waste ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment B ❑ Other: ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations ❑ Mortgage Foreclosure: Residential Restraining Order ❑ Mortgage Foreclosure: Commercial ❑ Quo Warranto PROFESSIONAL ❑ Partition ❑ Replevin LIABLITY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: ❑ Legal ❑ Medical ❑ Other Professional: Updated 1/1/2011 Our File No.: 385328r. L.'f' a'�r Apothaker Scian P.C. 'r C r(� lj i ' 15, By: David J. Apothaker, Esquire<,1 �( �,�j, ) J(�;, Attorney I.D. 438423 PE."�1S YLVM�dlr�, 520 Fellowship Road Suite C306, PO Box 5496 Mt. Laurel, NJ 08054-5496 (800) 672-0215 Attorneys for Plaintiff BARCLAYS BANK DELAWARE ) COURT OF COMMON PLEAS 125 S WEST STREET ) CUMBERLAND COUNTY WILMINGTON, DE 19801 ) NO.: Plaintiff, ) vs. ) JOSEPH H GERDES ) 472 NURSERY DR S ) MECHANICSBURG, PA 17055-7018 ) Defendant. ) 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. 1F 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 DS 34 S. BEDFORD ST. CARLISLE PA 17013 p1� ATr4 717-249-3166 e 11317A & -t!I 3 9qa Our File No.: 385328 Apothaker Scian P.C. By: David J. Apothaker, Esquire Attorney I.D.#38423 520 Fellowship Road Suite C306, PO Box 5496 Mt. Laurel, NJ 08054-5496 (800) 672-0215 Attorneys for Plaintiff BARCLAYS BANK DELAWARE ) COURT OF COMMON PLEAS 125 S WEST STREET ) CUMBERLAND COUNTY WILMINGTON, DE 19801 ) NO.: Plaintiff, ) VS. ) JOSEPH H GERDES ) 472 NURSERY DR S ) MECHANICSBURG, PA 17055-7018 ) Defendant. ) CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is BARCLAYS BANK DELAWARE, 125 S WEST STREET, WILMINGTON, DE 19801. 2. Defendant(s) is/are JOSEPH H GERDES ("Defendant"), an adult individual residing at 472 NURSERY DR S, MECHANICSBURG, PA 17055-7018. 3. At the special instance and request of Defendant, Plaintiff issued a credit account ("Account")to Defendant. 4. The Account number ends in 4077. 5. Defendant received, accepted and used the account by making purchases, balance transfers, and/or cash advances. 6. The account is in default due to Defendant's failure to make timely payments. 7. Although demand has been made, Defendant has failed to make payment of the amount due. 8. The amount due as of this date is $4,333.60. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $4,333.60 and requests this Court award costs to the extent permitted by applicable law. Apot aker S ian P.C. Atto ey fo Plaintiff A Law Firm E gage in Debt Colle 'on BY: David J. Apotha r, Esquire Our File No.: 385328 r 385.328 VERIFICATION eby state that I am C for Plaintiff. I hereby verify that, upon information and belief,the statements made in the foregoing Civil Action Complaint are true and accurate. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. Affiant Name New Castle County, DE Defendant's Name: JOSEPH H GERDES Account Number: ending in 4077 Subscribed and sworn to before me this ! day of �Gt��l 2o1y 44 Notary Public, County of New Castle, State of Delaware My commission expires: 1 I�YI(S ��\P 1NOONqI/i/�� ,•�MISS'!L /moi • 0 �o •� SXP14 2p15 _ 44, v• ��/ ••��TARYPJO�aPQ�\ 4 II��O��P�\��