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Home My WebLink About09-1642r.,, __r 1 Our File No.: 197829 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 ALLGATE FINANCIAL, LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Cq - 1(ou 0,-, V i l Ter o, MELISSA S SHOENBERGER 224 CHESTNUT ST MOUNT HOLLY SPRINGS, PA 17065 Defendant. 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.: 197829 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 ALLGATE FINANCIAL, LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. MELISSA S SHOENBERGER 224 CHESTNUT ST MOUNT HOLLY SPRINGS, PA 17065 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 9 - /4 qa 64u4 `T CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is ALLGATE FINANCIAL, LLC c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are MELISSA S SHOENBERGER, an adult individual residing at 224 CHESTNUT ST MOUNT HOLLY SPRINGS, PA 17065. 3. Plaintiff, ALLGATE FINANCIAL, LLC, is the Assignee and Successor in Interest of Account #2009080395703; and said account was issued to Defendant(s) by CITI FINANCIAL, 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 $2,066.68. 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 $2,066.68 and requests this Court award Plaintiff attorney's fees APOTHAKER & Attorney A Law Firm Enga? Dated: 3/9/2009 BY: David J. to the extent permitted by applicable law. Debt TES, P.C. Esquire Our File No.: 197829 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 the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating to unswom falsification to David J. ?pc Attorney ker, Esquire Plaintiff DATE: 3/9/2009 t . ALLGATE FINANCIAL, LLC MELISSA S SHOENBERGER 224 CHESTNUT ST MOUNT HOLLY SPRINGS, PA 17065 STATEMENT OF ACCOUNT Debtor's Name: MELISSA S SHOENBERGER Account Number: 2009080395703 Original Creditor: CITI FINANCIAL Balance Due: $2,066.68 Our File No.: 197829 EXHIBIT "A" (') 'v 17 ..p W r l ?g Sheriffs Office of Cumberland County R Thomas Kline ' 9'O'Otn of 4umbettEdward L Schorpp Sheriff Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFP CE OF THE S-ERIFF y Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 03/23/2009 08:30 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on March 23, 2009 at 2030 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Melissa Shoenberger, by making known unto Melissa Shoenberger personally, at 224 Chestnut Street, Apt. 2, Mt. Holly Springs, Cumberland County, Pennsylvania its contents and at the same time handing toyer personally the said true and correct copy of the same. SHERIFF COST: $33.40 March 24, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF puty S eriff Docket No. 2009-1642 Allgate Financial IW v Melissa S Shoenberger ?, i^ ?.. ? ? liZ ?- " T tai '? C_ -°?Rt G ,„ ?, ? '. ,. t?i,,