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Home My WebLink About09-4011Our Fill No.: 205771 APOTHAKER ?L 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. SEAN PFEIL 1414 SILVER CREEK DR MECHANICSBURG, PA 17050-2085 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0- H011 iIT er 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 Filt No.: 205771 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. ) SEAN PFEIL ) 1414 SILVER CREEK DR ) MECHANICSBURG, PA 17050-2085 ) Defendant. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: O 9- yo// T?-- 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 SEAN PFEIL, an adult individual residing at 1414 SILVER CREEK DR MECHANICSBURG, PA 17050-2085. 3. Plaintiff, CACH, LLC, is the Assignee and Successor in Interest of Account #4559908813266413; and said account was issued to Defendant(s) by WASHINGTON MUTUAL/PROVIDIAN 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 $4,835.98. 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 $4,835.98 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & Dated: 6/10/2009 Attorney A Law Firm Eng BY: David J. Ana TES, P.C. in Debt Collection , Esquire Our File No.: 205771 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 relatingPrpnsyiorn falsification to authorities. David J. Ap?thaker, Esquire Attorney fqr Plaintiff DATE: 6/10/2009 t? AFFIDAVIT OF SALE STATE OF: MARYLAND COUNTY OF: FREDERICK CHASE!„ I . I am authorized on behalf of Chase Bank USA, N.A. to make this affidavit. 2. SEAN PFEIL had a credit card account with Chase Bank USA, N.A., account number 4559908813266013. The account was sold and transferred to CACH, LLC on or about 512412046. At the time of the sale to CACH, LLC, the amount due on the account pursuant to the terms of the cardholder agreement between Chase Bank USA, N.A. and SEAN PFEIL was $4,004.15 Your deponent states that to the best of deponent's knowledge, information and belief that there was no unaccredited payment, just counterclaims or offsets against the account when it was sold. 3. Your deponent acknowledges that in making this affidavit that CACH, LLC is now the ow-ter of said account, and authorized to collect, settle, adjust, compromise and satisfy the same and that Chase Bank USA, N.A. has no further interest in said account for any purpose. Chase Bank USA. N.A Eric M. Walsh Team Leader On 3x'26!2009, before me appeared Eric M. Walsh personally known to me or proved to me on the basis of satisfactory evidence to be the individual(s) whose name(s) is (are) subscribe to the within instrument and acknowledged to me that heishe./they executed the same in hivlierltheir capacityies), and that by his/her/their signature(s) on the instrument, the individual(s), or the person upon behalf of which the individual(s) acted, executed the instrument. RUN E, WAHL Notary ubtic-Maryland, ?rodwrsrk gCountty 3 uary I , Mires E 0 :1 Notary Public CACH, LLC SEAN PFEIL 1414 SILVER CREEK DR MECHANICSBURG, PA 17050-2085 STATEMENT OF ACCOUNT Debtor's Name: SEAN PFEIL Account Number: 4559908813266013 Original Creditor: WASHINGTON MUTUAL/PROVIDIAN BANK Balance Due: $4,835.98 Our File No.: 205771 EXHIBIT "A" Q CF P 4RY 2009 J "iT•1 15 p j? 1: 5 5 F N $g8.5o Pp A`rT4 (;IalI3c1 e 2a(0135 Sheriffs Office of Cumberland County R Thomas Kline ,tit4 of c'a+tibi, Edward L Schorpp Sheri Solicitor Ronny R Anderson Jody S Smith Chief Deputy o IcE r''L SwERIFF Civil Process Sergeant Cach, LLC vs. Sean Pfeil Case Number 2009-4011 SHERIFF'S RETURN OF SERVICE 06/23/2009 10:43 AM - Jody Smith, Sergeant, who being duly sworn according to law, states that on June 23, 2009 at 1043 hours, she served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Sean Pfeil, by making known unto himself personally, defendant at 1 Courthouse Square, Room 303 Carlisle, Cumberland County, Pennsylvania 17013 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 June 23, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF BY Dep ?n uty Sheriff r, D .H