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Home My WebLink About08-1243Our File No.: 149605 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. SHAIN C CONNER 15 KENNETH AVE SHIPPENSBURG, PA 17257 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: oa - (&q3 Nit `Tern 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 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. SHAIN C CONNER 15 KENNETH AVE SHIPPENSBURG, PA 17257 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 S - /Z Y 3 CC -4 7-,t.- CIVIL ACTION COMPLAINT FIRST COUNT 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 SHAIN C CONNER, an adult individual residing at 15 KENNETH AVE SHIPPENSBURG, PA 17257. 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. leaving a balance due and owing of $3,517.22. In addition, Plaintiff avers that Defendant has failed and continues to fail to make any payments, " 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 $3,517.22 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney r laintiff A Law Firm Eng ed i Debt Collection BY: David Dated: 2/12/2008 Our File No.: 149605 VERIFICATION David J. Apothaker Esa 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 u 9grrn falsification to authorities. David J. Attorney for Plaintiff DATE: 2/12/2008 CACH, LLC. c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 SHAIN C CONNER 15 KENNETH AVE SHIPPENSBURG, PA 17257 STATEMENT OF ACCOUNT Debtor's Name: Account Number: Original Creditor: Balance Due: Our File No.: 149605 SHAIN C CONNER 4800113993181663 BANK OF AMERICA, N.A. $3,517.22 EXHIBIT "A" 3 rIZt C c l i ?c o0 t. ` 7 -? t t ?- O ^? U 1 C SHERIFF'S RETURN - REGULAR CASE NO: 2008-01243 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CACH LLC VS CONNER SHAIN C NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CONNER SHAIN C the DEFENDANT , at 1120:00 HOURS, on the 11th day of March , 2008 at 15 KENNETH AVE SHIPPENSBURG, PA 17257 SHAIN C CONNER 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 19.20 Affidavit .00 Surcharge 10.00 3//8)D8 0'-. x..2000 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 03/13/2008 APOTHAKER & ASSOCIATES By: Deputy Sheriff of A. D. Our File No.: 149605 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. VS. Plaintiff, SHAIN C CONNER Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF 1 CUMBERLAND COUNTY NO.: 08-1243 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, SHAIN C CONNER, in the default of an Answer, in the amount of $3,840.67 computed as follows: Amount claimed in complaint: $3,517.22 Amount Paid: - $(0.00) Interest from February 12, 2008 to 03/25/09 at the legal interest rate of 6.000 per annum $197.75 Attorney fees $0.00 TOTAL $3,714.97 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, SHAIN C CONNER, last know address is 15 KENNETH AVE SHIPPENSBURG, PA 17257. APOTHAKER,& ASSOCIATES, P.C. A Law Firm By: David J. Apothaker Dated: 3/25/2009 • Our Filb No.: 149605 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.: 08-1243 SHAIN C CONNER ) 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 15 KENNETH AVE SHIPPENSBURG, PA 17257. We inquired with the web site of the Boulevard, Suite 400, Arlington, VA 22209-25S Mary M. Snavely-Dixon, Director of the indicated that the Defendant(s) is/are not in the n Data Center, located at 1600 Wilson ) is/are in any branch of the military. data Center has sent back our inquiry David J. Apothaker Attorney for Plaintiff 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 MAR-25-200915:17:43 Upon searching the information data banks ofthe Department of Defense Mas power Data Center, based on the information that you provided, the above is the current status ofthe individual as to al branches ofthe Iiflitary. 4131 )4. 1 Mary It Snavely Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center(DMDC) is an organization of the Department ofDefmse that maintains the Defense EaroUment and Ek&6* Reporting System (DEERS) database which a the official source of data on a bdity for r ry medical care and other ekgbility systems. The Department of Defense stronghy supports the enforcement of the Servicemembers Civit ReliefAct [50 USCS Apps. §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil ReWAct 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 fang member, friend, or representative asserts many manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty statics by contac* that person's Mfitary Service via the 'deft mseink.mte URL provided below. If you have evidence the person is on active-duty and you fad to obtain this additional MNewy Service verification, provisions of the SC'RA may be invoked against you.. If you obtain further information about the person ( e.g,, an SSN, unproved accuracy of DOB, a middle name), you can vAaik 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 historicalinformatiori, please contact the Military Service SCRA poias- of-contact. See: :11w ww.defi=eWk.mi6ov a/FC:09SLDR bud WARNINCr 7b is certificate was provided based ou a name and Social Security number (SSN) provided by the requester. Providing an erroneous name or SSN wUi cause an erroneous certificate to be provided: R wt tl?_8GPAVVX"AFg 40 Miltacp Status Report Pursuant to the Servicemembers Civil Relief Act SHERIFF'S RETURN - REGULAR ?• CASE NO: 2008-01243 P "I'COMMONWEAI.LTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CACH LLC VS CONNER SHAIN C NOAH CLINE Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CONNER SHAIN C the DEFENDANT , at 1120:00 HOURS, on the 11th day of March , 2008 at 15 KENNETH AVE SHIPPENSBURG, PA 17257 by handing to SHAIN C CONNER 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 So Answers: R. Thomas Kline 03/13/2008 APOTHAKER & ASSOCIATES By of A. D. . , ,, . 149605 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY CACH, LLC. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) SHAIN C CONNER ) NO. 08-1243 To: SHAIN C CONNER 15 KENNETH AVE SHIPPENSBURG, PA 17257 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: June 18, 2008 IMPORTANT NOTICE LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FEE. 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 CUMBERLAND COUNTY ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 BAR is? DAVID J. APOTHAKER, 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 OF ? trNrt =APR -# Mi It 00 "IE MMM 4-14-00 Pu fkiT,t tarn 19 b.s 1 .6 . OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: SHAIN C CONNER 15 KENNETH AVE SHIPPENSBURG, PA 17257 CACH, LLC. ) COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, ) vs. ) NO.: 08-1243 SHAIN C CONNER ) 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, Es q. at this telephone number: 215-634-8920 149 ;a 'dk & A SO(AAIS. 1).t_ I=} I ),A id J "ipotl,tkc r. I SCILUN ? h1h 1011d ('306 V i;il? 1 ,. UW1. `.,I 'lsso-54 'ol, Pi Iih1? ?.1. Plailit It1f.. Defendant 213IL FEB 28 fjI i I CUMBERLAND COUNTY PENNSYLVANIA I 1 d(i. (?8- s 1 1 PRAECIPF, TO MARK JLDGMENT SATISFIED 11 ' T1 II PROTHONOTARY: Piva5e niark the Judgment Sajl,?fjed 3LLifljSt Cllt I)Ctelld',1I11. hld( I2lel l 11& LC?1 I <i3i? \Po I I1AKEK & IANSC)t_'I \ I1: . I'.(_ `?1((?I7li'V i•"I?OIt I'I«lill? a 1_.l?? I fiI?II1 I?TI`?y{` CC??711 I)ehl k10(1 Da-. iu J. AIlk h?Ii;??r. I t, ire a14 4 9 -so ?I (n o+109-n05LI ? ?., a--? I (A 13