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Home My WebLink About09-4010Out File No.: 207978 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 CACH, LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. JOSHUA P FICKES 26 HOLLAR AVE APT 1 SHIPPENSBURG, PA 17257 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: QQ - NO1O NOTICE 0,1VI Crerift 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.: 207978 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 CACH, LLC c/o Apothaker & Associates, P.C 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. JOSHUA P FICKES 26 HOLLAR AVE APT 1 SHIPPENSBURG, PA 17257 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0f- 1/B 1 c Culrl CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is CACH, LLC c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are JOSHUA P FICKES, an adult individual residing at 26 HOLLAR AVE APT 1 SHIPPENSBURG, PA 17257. 3. Plaintiff, CACH, LLC, is the Assignee and Successor in Interest of Account #5329064999245375; and said account was issued to Defendant(s) by MARYLAND NATIONAL BANK, 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 $4,736.68. 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 $4,736.68 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & Attorney A Law Firm Enea? BY: Dated: 6/10/2009 David J. ATES, P.C. Collection Our File No.: 207978 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 relating to V&w96 falsification to authorities. David J. Attorney for DATE: 6/10/2009 CACH, LLC JOSHUA P FICKES 26 HOLLAR AVE APT 1 SHIPPENSBURG, PA 17257 STATEMENT OF ACCOUNT Debtor's Name: JOSHUA P FICKES Account Number: 5329064999245375 Original Creditor: MARYLAND NATIONAL BANK, N.A. Balance Due: $4,736.68 Our File No.: 207978 EXHIBIT "A" c 21,09 5 P11 !: 54 418.5o PO A7W 0CP (X7 X34 Pte' A.Uq 30 Sheriffs Office of Cumberland County R Thomas Kline It, at ?Ilaritjpr d Sheriff Ronny R Anderson x Chief Deputy OFFICE of THE SHERIFF Edward L Schorpp Solicitor Jody S Smith Civil Process Sergeant Cach, LLC vs. Joshua P. Fickes Case Number 2009-4010 SHERIFF'S RETURN OF SERVICE 06/18/2009 06:25 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on June 18, 2009 at 1825 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Joshua P. Fickes, by making known unto himself personally, defendant at 26 Hollar Avenue, Apt. 1 Shippensburg, Cumberland County, Pennsylvania 17257 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $46.00 June 19, 2009 SO ANSWERS, rA000a*eVM"< 499f ?O R THOMAS KLINE, SHERIFF '?C C De uty Sheri f c7 ^a r a J 'I c -1 z? - _ rv -- m, - ny C' Z1 Law Firm of Allan C.Smith,P.0 Attorney I.D.No.204756 Law Firm of Allan C.Smith,P.C. 1276 Veterans Hwy,Suite E-1 Bristol,PA 19007 1-888-275-6399 H(215)428-0666 Attorney for Plaintiff , CACH,LLC ) DISTRICT COURT 4340 S. MONACO STREET ) COUNTY DENVER,CO 80237 ) r,.z a Plaintiff, ) rnw r c po Vs. ) No.: 09-4010 , JOSHUA P FICKES ) 115 W South St ) E `'•' - +` Carlisle,PA 17013 ) � ENTRY OF APPEARANCE TO THE PROTHONOTARY: Kindly enter my appearance on behalf of CACH,LLC, the plaintiff in this-action. All . Smith,Esq. I.D o.204756 Law Firm of Allan C. Smith,P.0 1276 Veterans Hwy-Suite E-1 Bristol,PA 19007 WITHDRAWAL OF APPEARANCE TO THE PROTHONOTARY: Kindly withdrawal my appearance on behalf of CACH,LLC,the plaintiff in this action. Michael F. McGuigan,Esq. I.D. #88954 P.O. Box 401 Richboro,PA 18954 Date: Law Firm of Allan C. Smith, P.C. Attorney I.D. #204756 Bucks County Office Center 1276 Veterans Highway, Suite E-1 Bristol, Pennsylvania 19007 Tel (215) 428-0666 / Fax (215) 428-0740 Attorney for Plaintiff CACH, LLC. 4340 S. MONACO STREET - 2ND FLOOR DENVER, CO 80237 VS. JOSHUA P FICKES Plaintiff(s), Defendant. 20/4 Peo,, 410 Cp Ai 14'y IN THE COURT OF COMMON PLEAS CUMBERLAND COUNTY, PENNSYLVANIA CIVIL ACTION DOCKET NO.: 09-4010 ORDER TO SATISFY OR SETTLE DISCONTINUE AND END TO THE PROTHONOTARY OF CUMBERLAND COUNTY: ® Kindly mark the Judgment in the above matter as Satisfied. This case is now closed. ❑ Kindly mark the above case Settled, Discontinued and Ended WITHOUT prejudice and without costs against either party. OR ❑ Please mark the above matter: Date: July 11, 2014 B A LAN C. SMITH, ESQ.