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Home My WebLink About08-4771 Our File No.: 174744 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 ELITE RECOVERY SERVICES INC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, vs. CHARLES E CAROTHERS 1909 RESERVOIR DR CARLISLE, PA 17013-1053 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 01- 'g111 NOTICE 0''1Vit Tcr*%- 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 W 4W APOTHA.KER & ASSOCIATES, P.C. BY: David J. Apothaker, Esq. Attorney LD.# 38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff ELITE RECOVERY SERVICES INC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, vs. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 t-' q7 7 1 c; vi I ftlK CHARLES E CAROTHERS 1909 RESERVOIR DR CARLISLE, PA 17013-1053 Defendant. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is ELITE RECOVERY SERVICES INC c/o Apothaker & Associates, P.C., 2417 Welsh Road, Suite 21 #520, Philadelphia, PA 19114. 2. Defendant(s) is/are CHARLES E CAROTHERS, an adult individual residing at 1909 RESERVOIR DR CARLISLE, PA 17013-1053. 3. Plaintiff, ELITE RECOVERY SERVICES INC, is the Assignee and Successor in Interest of Account #4862362313972856; and said account was issued to Defendant(s) by CAPITAL ONE BANK (USA), N.A., 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 $1,424.01. 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. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of 11 $1,424.01 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & A IATES, P.C. Attorney f r rh tiff ollection A Law Firm Eng d i t C BY: David J. Dated: 7/30/2008 Our File No.: 174744 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 subject to the penalties of 18 Pa.C.S.A. 4904 relating 1 David J. Apothaker Attorney for Plaintiff that the statements therein are made authorities. DATE: 7/30/2008 ELITE RECOVERY SERVICES INC CHARLES E CAROTHERS 1909 RESERVOIR DR CARLISLE, PA 17013-1053 STATEMENT OF ACCOUNT Debtor's Name: CHARLES E CAROTHERS Account Number: 4862362313972856 Original Creditor: CAPITAL ONE BANK (USA), N.A. Balance Due: $1,424.01 Our File No.: 174744 EXHIBIT "A" ra G "'C3 i7 ? 3r• 00 m C_ Q - i GJ LJ ? e Our File No.: 174744 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D.# 38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff ELITE RECOVERY SERVICES INC Plaintiff, vs. CHARLES E CAROTHERS Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-4771 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & A CIATES, P.C. Attorny or laintiff A Law Firm En; ged n Debt Collection By: David aker, Esquire Dated: 8/19/2008 ,{'gy`p r , SHERIFF'S RETURN - REGULAR CASE NO: 2008-04771 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ELITE RECOVERY SERVICES INC VS CAROTHERS CHARLES E MICHAEL BARRICK , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania,;whobeing duly sworn according to law, says, the within COMPLAINT & NOTICE, was served upon CAROTHERS CHARLES E the DEFENDANT , at 2102:00 HOURS, on the 14th day of August , 2008 at 1909 RESERVOIR DR CARLISLE, PA 17013-1053 by handing to DEBRA CAROTHERS, WIFE a true and attested copy of COM?LA1NT & NOTICE together with and at the same time directing Her lattention to the contents thereof. Sheriff's Costs: So Answers: Docketing 18.00 5.00 0-000 4e Service 5 ?. .00 Surcharge 10.00 R., Thomas Kline .00 33.00 08/2;1/2008 APOTHAKER & ASSOCIATES - Sworn and Subscibed to By:- before me this day Deputy Sheriff of A.D.