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Home My WebLink About08-1241,of Our File No.: 145833 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. STARLENE REED 4 RAYLEN DR BOILING SPRINGS, PA 17007-9773 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 08 JAq I 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 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 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. STARLENE REED 4 RAYLEN DR BOILING SPRINGS, PA 17007-9773 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 01- /2 V1 b;?j 1t4- 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 STARLENE REED, an adult individual residing at 4 RAYLEN DR BOILING SPRINGS, PA 17007-9773. 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 $2,415.75. 8. Although demand has been made, Defendant has failed to make payment of the amount due as above. 9. The original creditor is PROVIDIAN BANK. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $2,415.75 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney r Plaintiff A Law Firm Eng 'e in Debt Collection BY: Dated: 2/12/2008 Da Our File No.: 145833 VERIFICATION David J. Apothaker Esqhereby 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 yds om falsification to authorities. Attorftev for Plaintiff DATE: 2/12/2008 ft. CACH, LLC. c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 STARLENE REED 4 RAYLEN DR BOILING SPRINGS, PA 17007-9773 STATEMENT OF ACCOUNT Debtor's Name: STARLENE REED Account Number: 4559908483706934 Original Creditor: PROVIDIAN BANK Balance Due: $2,415.75 Our File No.: 145833 EXHIBIT "A" O rn Cu c il o ? Ln p G,?.7 ;?, ?r7 O SHERIFF'S RETURN - REGULAR CASE NO: 2008-01241 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CACH LLC VS REED STARLENE ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon REED STARLENE the DEFENDANT , at 1515:00 HOURS, on the 14th day of March , 2008 at 4 RAYLEN DR BOILING SPRINGS, PA 17007-9773 by handing to THOMAS PILLSBURY, BOYFRIEND ADULT IN CHARGE 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 ? 1/ 32.80 Sworn and Subscibed to before me this day of , So Answers: P R. Thomas Kline 03/17/2008 APOTHAKER & ASSOCIATES By: jdputy S eri f A.D. ? A Our File No.: 145833 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 CACH, LLC. Plaintiff, VS. STARLENE REED Defendant. TO THE PROTHONOTARY: Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-1241 Civil Action PRAEC1 PE FOR DEFAULT JUDGMENT Kindly enter judgment against Defendant, STARLENE REED, in the default of an Answer, in the amount of $2,678.67 computed as follows: Amount claimed in complaint: $2,415.75 Amount Paid: - $(0.00) Interest from February 12, 2008 to 03/25/09 at the legal interest rate of 6.000 per annum $151.62 Attorney fees $0.00 TOTAL $2,567.37 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, STARLENE REED, last know address is 4 RAYLEN DR BOILING SPRINGS, PA 17007-9773. Dated: 3/25/2009 APOTHAKER & A#Dt Attorne foA Law Firm Eng ged By: .C. Collection David J. Apothaker Our File No.: 145833 . 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.: 08-1241 STARLENE REED ) Civil Action Defendant. ) 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 4 RAYLEN DR BOILING SPRINGS, PA 17007-9773. We inquired with the web site of the Defense Boulevard, Suite 400, Arlington, VA 22209-2593, if the Mary M. Snavely-Dixon, Director of the indicated that the Defendant(s) is/are not in the i David J. A?,othaker Attorney for Plaintiff Data Center, located at 1600 Wilson is/are in any branch of the military. 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. ,+ Deparmunt of Defense Manpower Data Center MAR-25-2009 15:15:05 NWfty 40 Status Report Pursuant to the Servicemembers Civil Relief Act STARK Based on the infonaatzou you have fmuished, the DMDC does not possess any information sudicatiag that the indmduafl a currently on active duty. Upon searching the infomnation data backs ofthe Department of De£ensc Manpower Data Center, based on the irformationthat you provided, the above is the current status of tf a indiv dead as to all branches of the Military. )r), Mary M. Srwely-Dixon, Director Department of De€emse - Manpower Data Center 1600 Wilson Blvd, Sum 400 A ington, VA 22209-2593 The Defense Manpower Data Center (DIADC) is an organization of the DeparEtna t ofDefine thattus ntains slit Defense Enrollment and EbOx* Reporting System (DEERS) database which is the official source of data on egibky for military muedical care and other eligibility systems. The Departmment of Defense strov& supports the enforcemeiat of the Servicernembers Civil RelieefAct [50 USCS Appx g f 501 et seq] (SCRA) '(fon nedy the Soldiers' and Sailors' Civil ReliefAct of 1940). DMDC has issued bundmds of thousands of "does not possess any information indicating that the individual is currently on active duty' responses, and has eVerienced a small error rate. In the event the individual referenced above, or any family member, fiiend, or representative asserts in any manner than the individual is on active duty, or is otherwise entided to the protections ofthe SCRA, you are strongly encouraged to obtain firrther verification oft re person's active duty status by contacting that person's Mftwy Service via the 'defzmsl'mlcmfi' '[JILL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions ofthe 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 subcait your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Witary Service SCRA points- of-contact. See: ltto:llw ww.defe=eWc. ant GU9SLDR. t WAMWCr. This cent cafe was provided based on a tame and Social Security number (SM provided by the requester. Providing an erroneous name or SSH will cause an erroneous certificate to be provided. RVmfIb_RWOR RFOF SHERIFF'S RETURN - REGULAR YCASE NO : 2008-01241 P COMMONWEALTH OF PENNSYLVANIA: `J COUNTY OF CUMBERLAND CACH LLC VS REED STARLENE ROBERT BITNER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon REED STARLENE the DEFENDANT at 1515:00 HOURS, on the 14th day of March 2008 at 4 RAYLEN DR BOILING SPRINGS, PA 17007-9773 by handing to THOMAS PILLSBURY, BOYFRIEND ADULT IN CHARGE 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 .00 32.80 03/17/2008 APOTHAKER & ASSOCIATES Sworn and Subscibed to By: ,Ilk-s C---:zr;t" before me this day eputy S eri f of A.D. 145833 `- r CACH, LLC. vs. STARLENE REED To: STARLENE REED OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY COURT OF COMMON PLEAS CUMBERLAND COUNTY } NO. 08-1241 4 RAYLEN DR BOILING SPRINGS, PA 17007-9773 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: June 19, 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 ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 1s1 BAR DAVID J. APO MAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC 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 RUD4)M OF THE MODMURY 2 APR - i FM 1: 03 DiwaLg C ITY OMA 41tv oo PD pi" Goo Tana I q V` aa5o,76 . OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: STARLENE REED 4 RAYLEN DR BOILING SPRINGS, PA 17007-9773 CACH, LLC. VS. STARLENE REED NOTICE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, ) NO.: 08-1241 Civil Action Defendant. ) 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 Our File No.: 1458' )3 APOTIIAKER & 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 CACH, L.LC. Plaintiff, Defendant. vs. STARLENE REED t f i.. ? IZ FEB - I pp I : f 9 PENNSYLVANIA COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-1241 PRAECIPE TO MARK JUDGMENT SATISFIED TO THE PROTHONOTARY: Please mark the Judgment Satisfied against the Defendant. Judgment has been paid in full. APOTHAKER & Attorney A Law Firm En2a; By: David J. I )CIATES, P.C. laintiff Debt Collection , Esquire