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Home My WebLink About09-4298P Our File No.: 211630 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. WILLIAM R CHENOWETH 905 S 29TH ST CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Dl' lm?e b-o'l NOTICE T.tm 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.: 211630 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. WILLIAM R CHENOWETH 905 S 29TH ST CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. O ! i I-T?CN`' 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 WILLIAM R CHENOWETH, an adult individual residing at 905 S 29TH ST CAMP HILL, PA 17011. 3. Plaintiff, CACH, LLC, is the Assignee and Successor in Interest of Account #4888940998968198; 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 $8,139.55. 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 $8,139.55 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney for ai tiff A Law Firm Engage m bt Collection BY: Dated: 6/22/2009 David J. Our File No.: 211630 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 unpwom falsification to authorities. David J. for DATE: 6/22/2009 CACH, LLC WILLIAM R CHENOWETH 905 S 29TH ST CAMP HILL, PA 17011 STATEMENT OF ACCOUNT Debtor's Name: WILLIAM R CHENOWETH Account Number: 4888940998968198 Original Creditor: BANK OF AMERICA, N.A. Balance Due: $8,139.55 Our File No.: 211630 EXHIBIT "A" 211630 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 Plaintiff/s: Court Number: CACH, LLC Expiration Date: [Type of Action: ivil Action Defendant/s: WILLIAM R CHENOWETH Serve Upon: WILLIAM R CHENOWETH Address for Service: 905 S 29TH ST CAMP HILL, PA 17011 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 0 r LE ID-C 7 ?i-i ;"fly 2009 JJ11 2 55 FYi "3: 0 J 10f Sheriffs Office of Cumberland County R Thomas Kline `tti" ct lrltltr ?"jr/14 Edward L Schorpp Sheri Solicitor >. Ronny R Anderson Jody S Smith Chief Deputy OFD iCE c ',E S"ERI"F Civil Process Sergeant Cach, LLC Case Number vs. 2009-4298 William R. Chenoweth SHERIFF'S RETURN OF SERVICE 07/01/2009 01:50 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on July 1, 2009 at 1350 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: William R. Chenoweth, by making known unto himself personally, defendant at 905 S. 29th Street Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $41.50 July 02, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF Deputy Sheriff 0 r-17 r....: - c.n c~ ~~ ~S ,(~ C ~v~ Ll ~ w~ C~,~tiow~/?~ /tie ~2e,vi ~(3G.00 Gie2 ~<N~, ~ cou( I~iEM~ ~ l2lP~ Q~7~ ~~ g3 C~~~o~ p/,~,~- ~1a~ ~aay-~~~ oI Nd~A~o/~ ~ ~a2,~ PgyM€~u~ a,oo /~i'ta~//7i, /~uT /~i,E ~P~~,~ ~eu~~ tiar,~y~~~ Do so, ~~/~~/oy w,,,.a. Q uHO~~~s /~ ~JNs~~~ /'n~oK ErU~f 4ie 2~ ~NCa€NS~D 9,3a,ov g ~~9a~v~ ~ av.E/z e~ ~auih, /s s w~.s tier ~ ~~~~ Z8~9 AUG ~ 3 AM !U~ S~ CAIAL Our File No211630 CACH, LL Plaintiff vs. WILLIAM CHENOWETI-I Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY c c C- ?zc Z NO.: 2009-4298 r"'a "? r n M cry cv' o a -?+o Civil Action ? Q >C N CDC) --f PRAECIPE FOR LISTING CASE FOR ARGUMENT TO THE PROTHONOTARY OF CUMBERLAND COUNTY: Please list the within matter for the next Ar ument Court. 1. Matter to be Argued: Plaintiff's Motion for Summary Judgment 2. Counsel who will argue cases: A othaker Associates P.C. WILLIAM R CHENOWETH, Pro Se Attorneys r Plaintiff 520 Fellow hip Road C306 Mount Lau el, NJ 08054 (800) 672-C215 3. I 4. 905 S 29TH ST CAMP HILL, PA 17011 notify all parties in writing within two days that this case has been listed for t Court Date: August 26, 2011 APOTHAKER & ASSOCIATES, P.C. Attorney for Plaintiff A Law Firm Engaged in Debt Collection BY: enjami J. Cavallaro, Esquire Dated: Ju4e 30, 2011 CACH, LLC, IN THE COURT OF COMMON PLEAS OF Plaintiff CUMBERLAND COUNTY PENNSYLVAN$k , vs. CIVIL ACTION - LAW zM ` rj NO. 09-4298 CIVIL r WILLIAM R. CHENO WETH, -<> Defendant r" ' xc) IN RE: PLAINTIFF'S MOTION FOR SUMMARY JUDGMENT , BEFORE HESS, P.J. AND OLER J cz) 7 ORDER AND NOW, this 9 ` day of September, 2011, the motion of the plaintiff for Summary Judgment is GRANTED and judgment is entered in favor of the plaintiff and against the defendant in the amount of $8,139.55. BY THE COURT, Kevin /Jordan W. Felzer, Esquire 520 Fellowship Road C306 Mount Laurel, NJ 08054 For the Plaintiff William R. Chenoweth, Pro Se 905 S. 291" Street Camp Hill, PA 17011 Oqier-9/ ?a Hess, P. J. Am