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Home My WebLink About09-4295 Our File No.: 205404 APOTHAKER & ASSOCIATES, P.C. BY: David J. Alothaker, 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. RICHARD L EDGERTON 1810 CARLISLE RD CAMP HILL, PA 17011-5909 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 1141, t 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.: 205404 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. RICHARD L EDGERTON 1810 CARLISLE RD CAMP HILL, PA 17011-5909 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 6q-y/ -` v 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 RICHARD L EDGERTON, an adult individual residing at 1810 CARLISLE RD CAMP HILL, PA 17011-5909. 3. Plaintiff, CACH, LLC, is the Assignee and Successor in Interest of Account #4888937994186692; and said account was issued to Defendant(s) by BANK OF AMERICA, 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 $4,245.87. 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 $4,245.87 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney for Miff A Law Firm Enizaae m D bt Collection BY: Dated: 6/22/2009 David J. Apothaief, Esquire Our File No.: 205404 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 relatir}grfo unworn falsification to authorities. David J. ApA er, Esquire Attorney for Plaintiff DATE: 6/22/2009 CACH, LLC RICHARD L EDGERTON 1810 CARLISLE RD CAMP HILL, PA 17011-5909 STATEMENT OF ACCOUNT Debtor's Name: RICHARD L EDGERTON Account Number: 4888937994186692 Original Creditor: BANK OF AMERICA, N.A. Balance Due: $4,245.87 Our File No.: 205404 EXHIBIT "A" D 1 7 r t 1 IX YJ?v r ' t i .ye ;7W# Sheriffs Office of Cumberland County R Thomas Kline Q??tdp etutNbrrl,r? Edward L Schorpp Sheriff r Solicitor C. Ronny R Anderson Jody S Smith Chief Deputy OF?a;F OF -ERIPF Civil Process Sergeant Cach, LLC Case Number vs. Richard L. Edgerton 2009-4295 SHERIFF'S RETURN OF SERVICE 06/29/2009 01:59 PM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Richard L. Edgerton, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Richard L. Edgerton. Per current resident at 1810 Carlisle Road Camp Hill, PA 17011 the defendant Richard L. Edgerton, has not lived here in two years. An exact address is not availole. SHERIFF COST: $46.50 June 30, 2009 SO ANSJWRS, ?_ F ,TH/MAS KLINE, SHERIFF C) r 3 C) Our File No.: 205404 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. RICHARD L EDGERTON 1810 CARLISLE RD CAMP HILL, PA 17011-5909 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: A/1 M" ??"?/? l !-arm 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 TgUE COPY FROM FIECOP' e??ITit1? whemd' 1118 E L'to Set nd the 10i said Ceurt al Gar?Ik,le+ .?•? Pr hone"M Our File No.: 205404 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. RICHARD L EDGERTON 1810 CARLISLE RD CAMP HILL, PA 17011-5909 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 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 RICHARD L EDGERTON, an adult individual residing at 1810 CARLISLE RD CAMP HILL, PA 17011-5909. 3. Plaintiff, CACH, LLC, is the Assignee and Successor in Interest of Account #4888937994186692; and said account was issued to Defendant(s) by BANK OF AMERICA, 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 $4,245.87. 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 $4,245.87 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney for ff A Law Firm Engage m D bt Collection BY: Dated: 6/22/2009 David J. Apothakel,Esquire Our File No.: 205404 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 hue 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 relatiryg-fq unworn falsification to authorities. David J. Apo er, Esquire Attorney for Plaintiff DATE: 6/22/2009 CACH, LLC RICHARD L EDGERTON 1810 CARLISLE RD CAMP HILL, PA 17011-5909 STATEMENT OF ACCOUNT Debtor's Name: RICHARD L EDGERTON Account Number: 4888937994186692 Original Creditor: BANK OF AMERICA, N.A. Balance Due: $4,245.87 Our File No.: 205404 EXHIBIT "A" 205404 Request for Service R. Thomas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.6390 Fx: 717-240-6397 Plaintiffs: Court Number: CACH, LLC Expiration Date: Type of Action: Civil Action Defendants: RICHARD L EDGERTON Serve Upon: RICHARD L EDGERTON Address for Service: 1810 CARLISLE RD CAMP HILL, PA 17011-5909 Alternate Address for Service: Type of Service: ( ) Personal (X) Adult in Charge () Deputize () Certified Mail (} Posting Special Service Instructions: * * If service is to be made by deputized service to another county please specify which county Filing Attorney Information: Name: Apothaker & Associates, P.C. Address: 520 Fellowship Road C306 Mount Laurel, NJ 08054 Telephone: 215-634-8920