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Home My WebLink About07-7593A Our File No.: 127449 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esq. Attorney I.D.#38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff CACH, LLC c/o Apothaker & Associates, P.C 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, vs. THEODORE HILL 162 KEN LIN DR CARLISLE, PA 17015 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: b7 - '1583 C i vi l T rr vi 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. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral and Information Service 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse do estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o con un abogado v entregar a la corte en forma escrita sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del edemandante y requiere que usted compla con todas las provisions de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes pare usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral and Information Service 800-990-9108 I APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esq. Attorney I.D.#38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff CACH, LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, VS. THEODORE HILL 162 KEN LIN DR CARLISLE, PA 17015 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff, CACH, LLC, is a company with its principal place of business located at c/o Apothaker & Associates, P.C., 2417 Welsh Road, Suite 214520, Philadelphia, PA 19114. 2. Defendant is THEODORE HILL, an adult individual residing at 162 KEN LIN DR CARLISLE, PA 17015. 3. At the special instance and request of Defendant, Plaintiff sold and delivered to Defendant goods and/or services at the times, of the kinds, in the quantities, and for the prices set forth in Plaintiffs records. A true and correct copy of which is attached hereto, incorporated herein by reference and designated Exhibit "A". 4. Defendant received and accepted the goods and/or services described in Exhibit "A". 5. The prices set forth in Exhibit "A" are the fair, reasonable and market prices for said goods and/or services, and the prices which Defendant agreed to pay. 6. All credits, if any, to which Defendant is entitled, are set forth in Exhibit "A". 7. In addition, Plaintiff avers that Defendant has failed and continues to fail to make any payments, leaving a balance due and owing of $1,623.74. y 8. Although demand has been made, Defendant has failed to make payment of the amount due as above. 9. The original creditor is OFFICEMAX. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $1,623.74 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & SOCIATES, P.C. Attorne fo Plaintiff A Law Firm Ena a in Debt Collection BY: David J. A Dated: 12/6/2007 Our File No.: 127449 VERIFICATION David J. Apothaker, 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 ysorn falsification to authorities. David I`Apothaker Attorney for Plaintiff DATE: 12/6/2007 CACH, LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 THEODORE HILL 162 KEN LIN DR CARLISLE, PA 17015 STATEMENT OF ACCOUNT Debtor's Name: THEODORE HILL Account Number: 6011617250479263 Original Creditor: OFFICEMAX Balance Due: $1,623.74 Our File No.: 127449 EXHIBIT "A" Q -o n ly x, ?? ? ?E.,1 C7 n ?t .? C-n SHERIFF'S RETURN - REGULAR CASE NO: 2007-07593 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CACH LLC VS HILL THEODORE STEPHEN BENDER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HILL THEODORE the DEFENDANT , at 0925:00 HOURS, on the 27th day of December , 2007 at 162 KEN LIN DRIVE CARLISLE, PA 17015 THEODORE HILL by handing to a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 4.80 Affidavit .00 Surcharge 10.00 .00 32.80 Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 12/28/2007 APOTHAKER & ASSOCIATES B%` f i?= Deputy Sheriff A. D. • j Our File No.: 127449 APOT14AKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 CACH, LLC VS. Plaintiff, THEODORE HILL Defendant. TO THE PROTHONOTARY: Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 07-7593 Civil Action PRAECIPE FOR DEFAULT JUDGMENT Kindly enter judgment against Defendant, THEODORE HILL, in the default of an Answer, in the amount of $1,846.77 computed as follows: Amount claimed in complaint: $1,623.74 Amount Paid: - $(0.00) Interest from December 06, 2007 to 04/08/09 at the legal interest rate of 6.000 per annum $111.73 Attorney fees $0.00 . TOTAL $1,735.47 I hereby certify that the appropriate Notices of Default, as attached have been mailed in accordance with Pa.R.Civ.P. 237.1 on the dates indicated on the Notices. I certify Defendant, THEODORE HILL, last know address is 162 KEN LIN DR CARLISLE, PA 17015. APOTHAKER & S IATES, P.C. Attorney for aintiff A Law Firm Ent tied ' Debt Collection By: David R Dated: 4/8/2009 I Our File No.: 127449 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff CACH, LLC Plaintiff, VS. THEODORE HILL Defendant. Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND . SS. David J. Apothaker, being duly sworn according to law, deposes and says that I am the attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 162 KEN LIN DR CARLISLE, PA 17015. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-2593, if the De"ant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the indicated that the Defendant(s) is/are not in the i COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 07-7593 David J. pothaker Attorney r Plaintiff Data Center has sent back our inquiry The above signed understands that the statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Department of Defense Manpower Data Center APR-08-200915.56;22 40 )may Status Report Pursuant to the Servicemembers Civil Relief Act rr 77, 777 T-77 7- 77 b "ms"s" ",,.7= 40, s, cif, Ss': Him iTHEODOU Based on the information you have finished, the DMDC does not possess any infonnation t indicating that the individual is curre ly on active duty. Upon searching the information data banks ofthe Depadtment of Defense Manpower Data Center, based on the inforsnation that you provided, the above is the current status of the individual as to all branches of the Military. 01 jov Mary M. Snavely-Dixon, Director Department of Defense Manpower Data Center 1600 VIJ%on Blvd- Suite 400 Arvin, VA 22209-2593 The Defense Manpower Data Center (DMDG') is an option of the Depatimes it of Defense the maintains the Defense Enrollment and EhSN ity Reporting System (DEERS) database which is the official source of data on eigibilityfor military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Apps. §§ 501 et seq] (SCRA) (f'ormedy the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of'does not possess any information indicating that the individual is currently on active duty' responses, and has experienced a small error rate- In the event the individual referenced above, or any fsmmly member, friend, or representative asserts in any manner that the individual is on active duty or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain figther verification of the person's active duty status by contacting that person's MiRa y Service via the 'def'enselinkmd' URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional hdiliry Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can subs your request again at this Web site and we will provide a now certificate for that query. This response reflects current active duty status only, For historical information, please contact the Mitary Service SCRA points- of=contact. See: httyl/www.def msehokm tyi&TC09SLDR,htant WA?"G'Th s certificate pravidcd based ou a naxmc,and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSW will cause an erroneous certificate to be provided RepartJV:Wi WZ Our File No.: 127449 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.#38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff CACH, LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, VS. THEODORE HILL 162 KEN LIN DR CARLISLE, PA 17015 Defendant. NO. 07-7593 NOTICE OF INTENTION TO TAKE DEFAULT TO: THEODORE HILL DATE OF NOTICE: January29, 2008 IMPORTANT NOTICE You are in default because you have failed to enter a written appearance personally or by attorney and file in writing with the court your defenses or objections to the claims set forth against you. Unless you act within ten (10) days from the date of this notice as set forth above, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral and Information Service 800-990-9108 DAVID J. APOTHAKER, ESQUIRE A Law Finn Engaged in Debt Collection 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff Attorney ID #38423 SHERIFF'S RETURN - REGULAR CASE NO 2007-07593 P' COMMONWEALTH OF PENNSYLVANIA- COUNTY OF CUMBERLAND CACH:LLC V HILL THEODORE STEPHEN BENDER Sheriff or Deputy Sheriff of Cumberland County,Pennsyltrania, who. being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon HILL THEODORE the DEFENDANT at 0925;00 HOURS, on the 27th day of December.,. 2007 at 162 KENT LIN DRIVE CARLISLE, PA 17015 by handing to THEODORE HILL A true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof.. Sheriff's Costs So Answers: Docketing 18.00 Service 4.80 Affidavit. .00 , Surcharge 10.00 R. Thomas Kline Q0 32,80 12128/2007 APOTHAKER & ASSOCIATES' Sworn and Subscibed tof By: before :me this day ep y Sheriff of , A.D. FILED-4DF7-i,.?VC,F OF ?F tpn?T r;??ONRY 2009 APR 14 P 2: 2 0 414 -CO P 0 RTT*4 ,--1 &01(000 p3# -70' TO: THEODORE HILL 162 KEN LIN DR CARLISLE, PA 17015 CACH,LLC Plaintiff, vs. THEODORE HILL OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 07-7593 Civil Action Defendant. NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. XX JUDGMENT BY DEFAULT JUDGMENT IN REPLEVIN JUDGMENT BY CONFESSION JUDGMENT FOR POSSESSION JUDGMENT ON AWARD OF ARBITRATORS _ JUDGMENT ON VERDICT JUDGMENT ON COURT FINDINGS - JUDGMENT ON WRIT OF REVIVAL IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker, Esc. at this telephone number: 215-634-8920 1 J