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Home My WebLink About08-06904L Our File No.: 144438 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. JOHN G WELSH 225 LEE CT ENOLA, PA 17025-1500 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0$- AD 0'iV1 l -T?xgn 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 ]a 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 cone puede decidir a favor del edemandante y requiere que usted compla con todas las provisioner 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 M 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. JOHN G WELSH 225 LEE CT ENOLA, PA 17025-1500 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: OX - I. f0 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 21 #520, Philadelphia, PA 19114. 2. Defendant is JOHN G WELSH, an adult individual residing at 225 LEE CT ENOLA, PA 17025- 1500. 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 $9,216.39. •n 8. Although demand has been made, Defendant has failed to make payment of the amount due as above. 9. The original creditor is BANK OF AMERICA, N.A.. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $9,216.39 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & Attorney A Law Firm Engal BY: Dated: 1/22/2008 )CIATES, P.C. aintiff Debt Collection David.P Our File No.: 144438 46 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 unworn falsification to authorities. DATE: 1/22/2008 Attorney for Plaintiff CACH, LLC. c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 JOHN G WELSH 225 LEE CT ENOLA, PA 17025-1500 STATEMENT OF ACCOUNT Debtor's Name: JOHN G WELSH Account Number: 4888930995384622 Original Creditor: BANK OF AMERICA, N.A. Balance Due: $9,216.39 Our File No.: 144438 EXHIBIT "A" Cl? t;7 C. ^' 'r'p, c_ FT, ? ? tv 0 SHERIFF'S RETURN - REGULAR CASE NO: 2008-00690 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CACH LLC VS WELSH JOHN G KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon WELSH JOHN G the DEFENDANT , at 1535:00 HOURS, on the 19th day of February-, 2008 at CUMBERLAND COUNTY NURSING HOME 1000 CLAREMONT ROAD ROOM 419 CARLISLE. PA 17013-1500 by handing to JOHN G WELSH 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 Service Affidavit Surcharge So Answers: 18.00 19.20 > .00 10.00 R. Thomas Kline .00 v"47.20 02/20/2008 APnTNAV7P 9, Agqr) 'TATR.C Sworn and Subscibed to By: before me this day of A.D. r y Our File No.: 144438 '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. ) COURT OF COMMON PLEAS OF Plaintiff, VS. JOHN G WELSH Defendant. TO THE PROTHONOTARY: CUMBERLAND COUNTY NO.: 08-690 Civil Action PRAECIPE FOR DEFAULT JUDGMENT Kindly enter judgment against Defendant, JOHN G WELSH, in the default of an Answer, in the amount of $9,936.39 computed as follows: Amount claimed in complaint: $9,216.39 Amount Paid: - $(0.00) Interest from January 22, 2008 to 03/25/09 at the legal interest rate of 6.000 per annum $594.30 Attorney fees $0.00 TOTAL $9,810.69 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, JOHN G WELSH, last know address is 225 LEE CT ENOLA, PA 17025-1500. APOTHAKER & "SIATES, P.C. A Law Firm Ent aced iO Debt By: David J. Dated: 3/25/2009 Our Fi1F No.: 144438 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. ) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, ) vs. ) NO.: 08-690 JOHN G WELSH ) Civil Action Defendant. ) AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA . SS. COUNTY OF CUMBERLAND 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 225 LEE CT ENOLA, PA 17025-1500. We inquired with the web site of the Boulevard, Suite 400, Arlington, VA 22209-25 Data Center, located at 1600 Wilson o) 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 David J. Apothaker Attorney for 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 ofDefense Manpower Data Center MAR-25-200915:12:34 Upon searching the information data banks ofthe Department of Defense Manpower Data Center, based on the irformat on that you provided, the above is the current status of the individual as to &2 branches of the Military. $hot A V L....j - '11- ;_ Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 iii sore Blvd., Suite 400 Win, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organi ation of the Deparlmenit of Defense Out mains the Defense Enrollment and E4g6* Reporting System (DEERS) database which a the official source of data on eligibd tyfor military medical cage and other el?oty systems.. The Department ofDefense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Apps` §§ 501 et seq] (SCRA) (formerly the Soldiers` and Sailors' Civil ReliefAct of 1940). DIADC has issued hundreds of thousands of `does not possess any information indicating that the individual is currre* on active quay' responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, fiend, 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 firether verification ofthe person's active duty status by contacting that person's MiJitary Service aria the "def msefinkmil" URL provided below. If you have evidence the person is on active-duty and you fid to obtain this additional Military Service verffication, provisions of the SCRA'may be invoked against you. If you obtain further infoxnnatiad about the person (e.g., an SSN, unproved accuracy of DOB, a middle name). you can submit your request again at this Web site and we wi l provide a new certificate for that query . "This response reflects current active duty status only. For historical infmnation, please contact the MItary Service SCRA points- of-contact. See: •Ilwww defensehnlc.rilfaahv sMC09SLDR.lrtrnT WARN1Na.. This certificate was provided based on a name and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSN will cause an erroneous certificate to be provided. R e p o r r i a B RW Omt r Military 40 Status Report Pmmnd to the Servicemembers Civil Relief Act SHERIFF'S RETURN REGULAR .V CASE NO: 2008-00690 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CACH LLC VS WELSH JOHN G KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon WELSH JOHN G the DEFENDANT , at 1535:00 HOURS, on the 19th day of February., 2008 at CUMBERLAND COUNTY NURSING HOME 1000 CLAREMONT ROAD ROOM 419 CARLISLE, PA 17013-1500 by handing to JOHN G WELSH 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 19.20 Affidavit ,00 Surcharge 10.00 .00 47.20 Sworn and Subscibed to before me this day of So Answers: R. Thomas Kline 02/20/2008 APOTHAKED & ASSOCIATES By: A. D. 144438 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY CACH, LLC. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) JOHN G WELSH ) NO. 08-690 To: JOHN G WELSH 225 LEE CT ENOLA, PA 17025-1500 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: April 23, 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 DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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 Lawyer Referral and Information Service 800-990-9108 1S I DAVID J. APOTHAKER, ESQUIRE A Law Firm Engaged in Debt Collection 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff Attorney ID #38423 g rM it 06 Po ATC`f 4t*.oo aa3oq'1 W?. L d R,?eQ T TO: JOHN G WELSH 225 LEE CT ENOLA, PA 17025-1500 CACH, LLC. Plaintiff, VS. JOHN G WELSH Defendant. OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-690 Civil Action 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, Esq, at this telephone number: 215-634-8920