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Home My WebLink About08-3900 Our File No.: 165683 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 ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC c/o Apothaker & Associates, P.C 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, VS. GLENN J CAPLAN 1933 CHATHAM DR CAMP HILL, PA 17011-5917 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: OE- 39n Ck 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. 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 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 \' 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 ATLANTIC CREDIT & FINANCE INC. ) ASSIGNEE FROM HSBC ) c/o Apothaker & Associates, P.C. ) 2417 Welsh Road, Suite 21 #520 ) Philadelphia, PA 19114 ) Plaintiff, ) VS. ) GLENN J CAPLAN ) 1933 CHATHAM DR ) CAMP HILL, PA 17011-5917 ) Defendant. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 4 F,- 3 9 " &LZI -TZ, , CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC c/o Apothaker & Associates, P.C., 2417 Welsh Road, Suite 21 #520, Philadelphia, PA 19114. 2. Defendant(s) is/are GLENN J CAPLAN, an adult individual residing at 1933 CHATHAM DR CAMP HILL, PA 17011-5917. 3. Plaintiff, ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC, is the Assignee and Successor in Interest of Account #5440455010141706; and said account was issued to Defendant(s) by HSBC, the Original creditor. 4. Defendant received, accepted and used the account to its benefit. 5. This account is in default and Defendant(s) has an unpaid balance of $3,296.00. A true and correct copy of the total due and owing is attached hereto, made a part hereof and marked as Exhibit "A". 6. All credits, if any, to which Defendant(s) is entitled, have been applied to the account and are included in Exhibit "A". 7. Although demand has been made, Defendant(s) has failed to make payment of the amount due as above. k. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $3,296.00 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney for Plaintiff A Law Firm Enp in Debt Collection BY: David P Dated: 6/23/2008 Our File No.: 165683 VERIFICATION David J. Anothaker Esg 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) 4worn falsification to authorities. David J. A-Prothaker Attorney for Plaintiff DATE: 6/23/2008 ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC GLENN J CAPLAN 1933 CHATHAM DR CAMP HILL, PA 17011-5917 STATEMENT OF ACCOUNT Debtor's Name: GLENN J CAPLAN Account Number: 5440455010141706 Original Creditor: HSBC Balance Due: $3,296.00 Our File No.: 165683 EXHIBIT "A" cs N ; CAZ) c ai : =.,. Ct JJ _ Cl) ?J CASE NO: 2008-03900 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ATLANTIC CREDIT & FINANCE INC VS CAPLAN GLENN J TIMOTHY REITZ , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon CAPLAN GLENN J the DEFENDANT , at 0012:59 HOURS, on the 12th day of July , 2008 at 1933 CHATHAM DR CAMP HILL, PA 17011-5917 by handing to GLENN J. CAPLAN DEFENDANT 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 14.00 Affidavit .00 Surcharge 10.00 7?/s?d Y ?-• 42.00 -'o Sworn and Subscibed to before me this day of , So Answers: Rit Thomas K in 07/14/2008 APOTHAKER & ASSOCIATES r--- By: D uty her' f A.D. 'OF P Our File No.: 165683 APOTHAKER & 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 ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, VS. NO. 08-3900 GLENN J CAPLAN Defendant. PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorne for /Plaintiff A Law Firm En age m Debt Collection By: David J. Apothaker, Esquire Dated: February 9, 2009 } rv r=_ C-1