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Home My WebLink About09-2079Our File No.: 203 527 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 ADVANTAGE ASSETS II, INC. c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. DARLENE M HECKARD 214 CONODOGUINET AVE CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: N -,,1019 Ct V{ e 'r- 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 1 14 Our File No.: 203527 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 ADVANTAGE ASSETS H, INC. c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. DARLENE M HECKARD 214 CONODOGUINET AVE CAMP HILL, PA 17011 Defendant. 1. Plaintiff is ADVANTAGE ASSETS II, INC. c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are DARLENE M HECKARD, an adult individual residing at 214 CONODOGUINET AVE CAMP HILL, PA 17011. 3. Plaintiff, ADVANTAGE ASSETS II, INC., is the Assignee and Successor in Interest of Account #1150087059319; and said account was issued to Defendant(s) by SEARS PREMIER CARD, 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 $1,050.67. 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 $1,050.67 and requests this Court award Plaintiff attorney's fees NO.: 0,7_ a2 0 7 9 -7L, CIVIL ACTION COMPLAINT FIRST COUNT COURT OF COMMON PLEAS CUMBERLAND COUNTY to the extent permitted by applicable law. APOTHAKER & Attorney A Law Firm Enaw Dated: 3/30/2009 BY: David J TES, P.C. Esquire Our File No.: 203527 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 that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relating to unworn i4 J. Apothaker, Esquire Attorney for Plaintiff DATE: 3/30/2009 ADVANTAGE ASSETS H, INC. DARLENE M HECKARD 214 CONODOGUINET AVE CAMP HILL, PA 17011 STATEMENT OF ACCOUNT Debtor's Name: DARLENE M HECKARD Account Number: 1150087059319 Original Creditor: SEARS PREMIER CARD Balance Due: $1,050.67 Our File No.: 203527 EXHIBIT "A" Qs) ALMORM OF THE 209 APR -2 PM 1: 26 CUM UIOUN l y PEINNNSYLVA to 4']8.50 Pb AYN Cj( Wagg at as31so She?Eiff s Office of Cumberland County R Thomas Kline ? .ter of ctutrbrr/ah Edward L Schorpp Sheri Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE ? s"ERiFr Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/06/2009 05:44 PM - Dennis Fry, De uty Sheriff, who being duly sworn according to law, states that on April 6, 200E at 1744 hours, he served a true copy of the within Complaint and Notice upon the within named defendant to wit: Darlene M. Heckard by making known unto Darlene M. Heckard, at 214 Condoguinet Avenue, Camp Hill, Cumberland County, Pennsylvania, 17011 its contents and at the same time handing to her personally the said true an correct copy of the same. SHERIFF COST: $39.70 SO ANSWERS, April 07, 2009 R THOMAS KLINE, SHERIFF Dep y Sher Docket No. 2009-2079 Advantage Assetts v Darlene . Heckard OF THE PPCW,"'ki4OTARY 2009 APR --9 AM 9: 52 Our File No.: 203527 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 ADVANTAGE ASSETS II, INC Plaintiff, VS. DARLENE M HECKARD Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-2079 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attom s r Plaintiff A Law Firm E Rad d in Debt Collection By: David J. Apothaker, Esquire Dated: June 4, 2009 PILED - :u riCE OF THE; 2009 JUIN I I PSI 2: 3 9 Cumar 4 _ ; 'i J iJ `Ul YIY