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Home My WebLink About08-6540e Our File No.: 188030 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff PINNACLE CREDIT SERVICES LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. CHRISTOPHER B THOMAS & IRMA B THOMAS 1361 ZIMMERMAN RD CARLISLE, PA 17015-9246 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 08 - (o5M0 3vit-FeTs' 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 i Our File No.: 188030 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff PINNACLE CREDIT SERVICES LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. CHRISTOPHER B THOMAS & IRMA B THOMAS 1361 ZIMMERMAN RD CARLISLE, PA 17015-9246 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: oj- 4 jrgo - ? '-7-A4.- CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is PINNACLE CREDIT SERVICES LLC c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are CHRISTOPHER B THOMAS & IRMA B THOMAS, an adult individual residing at 1361 ZIMMERMAN RD CARLISLE, PA 17015-9246. 3. Plaintiff, PINNACLE CREDIT SERVICES LLC, is the Assignee and Successor in Interest of Account #5407915003380307; and said account was issued to Defendant(s) by HOUSEHOLD BANK, 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 $1,952.13. 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". s 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 $1,952.13 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER SOCIATES, P.C. Atto ey f r Plaintiff A Law Firm En a? d in D Collectioi BY: David J. Apothaker, Esquire Dated: 10/28/2008 Our File No.: 188030 VERIFICATION David J. Apothaker, Esquire 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 rely to unworn falsification to authorities. David J. Apofiaker, Esquire Attorney for Plaintiff DATE: 10/28/2008 4 • . 4L PINNACLE CREDIT SERVICES LLC CHRISTOPHER B THOMAS & IRMA B THOMAS 1361 ZIMMERMAN RD CARLISLE, PA 17015-9246 STATEMENT OF ACCOUNT Debtor's Name: CHRISTOPHER B THOMAS & IRMA B THOMAS Account Number: 5407915003380307 Original Creditor: HOUSEHOLD BANK Balance Due: $1,952.13 Our File No.: 188030 EXHIBIT "A" oc o C7 VF - ? ?J f?1 MW CASE NO: 2008-06540 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PINNACLE CREDIT SERVICES LLC VS THOMAS CHRISTOPHER B ET AL MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE THOMAS CHRISTOPHER B was served upon the DEFENDANT , at 1506:00 HOURS, on the 7th day of November-, 2008 at 1361 ZIMMERMAN RD CARLISLE, PA 17015-9246 RANDALL THOMAS, SON 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: So Answers: Docketing 18.00 Service 7.00 Affidavit .00 Surcharge 10.00 R. Thomas Kline 00 +i jl F?Op- 35.00 11/12/2008 APOTHAKER & ASSOC TES Sworn and Subscibed to By _ before me this day Deputy Sheri f of A. D. I ,t SHERIFF'S RETURN - REGULAR CASE NO: 2008-06540 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PINNACLE CREDIT SERVICES LLC VS THOMAS CHRISTOPHER B ET AL MICHAEL BARRICK Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE THOMAS IRMA B the DEFENDANT , at 1506:00 HOURS, on the 7th day of November-, 2008 at 1361 ZIMMERMAN RD CARLISLE, PA 17015-9246 was served upon by handing to RANDALL THOMAS, SON a true and attested copy of COMPLAINT & NOTICE , Sheriff or Deputy Sheriff of together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: So Answers: Docketing 6.00 Service .00 , Affidavit .00 Surcharge 10.00 ,Thomas Kline .00 16.00 11/12/2008 APOTHAKER & ASSOCIAT S Sworn and Subscibed to By: before me this day Deputy Sheriff of A.D. Our File No.: 188030 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 PINNACLE CREDIT SERVICES LLC Plaintiff, VS. CHRISTOPHER B THOMAS & IRMA B THOMAS Defendant COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-6540 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plai iff A Law Firm Engaged in e t Collection By: David J. Dated: February 19, 2009 i