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Home My WebLink About08-6810 1 Our File No.: 188511 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 WORLDWIDE ASSET PURCHASING,LLC c/o Apothaker & Associates, P.C 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. STEPHANIE CLUGH 510 SHIPPENSBURG RD NEWVILLE, PA 17241 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: p$ - 10 810 Civi 1 Tie m 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 Our File No.: 188511 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 WORLDWIDE ASSET PURCHASING,LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. STEPHANIE CLUGH 510 SHIPPENSBURG RD NEWVILLE, PA 17241 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Op. (.41D CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is WORLDWIDE ASSET PURCHASING,LLC c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are STEPHANIE CLUGH, an adult individual residing at 510 SHIPPENSBURG RD NEWVILLE, PA 17241. 3. Plaintiff, WORLDWIDE ASSET PURCHASING,LLC, is the Assignee and Successor in Interest of Account #5410581848071421; and said account was issued to Defendant(s) by DIRECT MERCHANT, 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 $5,214.85. 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 $5,214.85 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. AFUIHAKE ASSOCIATES, P.C. Atte for Plaintiff A Law Firm na ed in Debt-`'nllectinI BY: David J. "Apothaker, Esquire Dated: 11/10/2008 Our File No.: 188511 ?N VERIFICATION David J. Anothaker 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 relpfif'ng ? unworn falsification to authorities. David J. AP'Othaker, Esquire Attorney for Plaintiff DATE: 11/10/2008 WORLDWIDE ASSET PURCHASING,LLC STEPHANIE CLUGH 510 SHIPPENSBURG RD NEWVILLE, PA 17241 STATEMENT OF ACCOUNT Debtor's Name: STEPHANIE CLUGH Account Number: 5410581848071421 Original Creditor: DIRECT MERCHANT Balance Due: $5,214.85 Our File No.: 188511 EXHIBIT "A" ?p 0 n C 0 0 1, O ? i T a SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-06810 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND WORLDWIDE ASSET PURCHASING LLC VS CLUGH STEPHANIE R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT CLUGH STEPHANIE but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE , the within named DEFENDANT , CLUGH STEPHANIE 510 SHIPPENSBURG RD NOT FOUND , as to NEWVILLE, PA 17241 PER DAUGHTER, DEFEDANT LIVES IN MARYLAND. Sheriff's Costs: Docketing 18.00 Service 13.00 Not Found 5.00 Surcharge 10.00 .00 46. 00 So answers : x. lrromas xilne i f of Cumberland County APOTHAKER & ASSOCIATES 11/20/2008 Sworn and Subscribed to before me this day of A. D. r f 416 Our File No.: 188511 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 WORLDWIDE ASSET PURCHASING,LLC Plaintiff, VS. STEPHANIE CLUGH Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-6810 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & A CIATES, P.C. Attorneys or P aintiff A Law Firm Eng ed ' Debt Collection By: David J. Apothaker, Esquire Dated: 1/8/2009 1 .ate co