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Home My WebLink About09-4304,Our File No.: 205520 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. JONATHAN D SIMON 885 TORWAY RD GARDNERS, PA 17324 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. Qg - t/&/) t/ C'%v a t-'a`r?'1 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.: 205520 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. ) ) JONATHAN D SIMON 885 TORWAY RD ) GARDNERS, PA 17324 ) Defendant. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 6q- X30 tl «,:I 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 JONATHAN D SIMON, an adult individual residing at 885 TORWAY RD GARDNERS, PA 17324. 3. Plaintiff, CACH, LLC, is the Assignee and Successor in Interest of Account #5427753037011879; and said account was issued to Defendant(s) by METRIS, 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 $2,169.16. 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 $2,169.16 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorney for P tiff A Law Firm Engage on ebt Collection BY: Dated: 6/22/2009 David J. Apktli?1?e rte, Esquire Our File No.: 205520 VERIFICATION David J. A othaker 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 falsification to authorities. DATE: 6/22/2009 CACH, LLC JONATHAN D SIMON 885 TORWAY RD GARDNERS, PA 17324 STATEMENT OF ACCOUNT Debtor's Name: JONATHAN D SIMON Account Number: 5427753037011879 Original Creditor: METRIS Balance Due: $2,169.16 Our File No.: 205520 EXHIBIT "A" 0 *'18.5o Pp ATT4 13894 4 ? d??a33 R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Cach, LLC vs. Jonathan D. Simon 06/27/2009 SHERIFF COST: $37.90 SO ANSWERS, June 29, 2009 ;LINE, SHERIFF lZz: Dep uty Sheriff F ? C7 Sheriffs Office of Cumberland County, ?4tt?tt?, pi ?araral?fl.?r,?d Edward L Schorpp Solicitor Jody S Smith Civil Process Sergeant Case Number 2009-4304 SHERIFF'S RETURN OF SERVICE 10:46 AM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on June 27, 2009 at 1046 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jonathan D. Simon, by making known unto himself personally, defendant at 885 To w Road Gardners, Cumberland County, Pennsylvania 17324 its contents and at the same time handing to him personally the said true and correct copy of the same. rvvay • r Our File No.: 20520 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 CACH, LLC vs. JONATHAN D SIMON Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-4304 Civil Action PRAECIPE FOR DEFAULT JUDGMENT Plaintiff, TO THE PROTHONOTARY: Kindly enter judgment against Defendant, JONATHAN D SIMON, in the default of an Answer, in the amount of $2,309.88 computed as follows: Amount claimed in complaint: $ 2,169.16 Less: Amount Paid: ( 0.00) Plus: Interest from June 22, 2009 to August 20, 2009 at the legal interest rate of 6.00% per annum 20.72 Attorney fees 0.00 TOTAL $ 2,309.88 I hereby certify that the appropriate Notices of Default, as attached have been mailed in accordance with Pa.R.Civ.P. 237.1 on the dates indicated on the Notices. I certify Defendant, JONATHAN D SIMON, last known address is 885 TORWAY RD GARDNERS, PA 17324. APOTHAKER OCIATES, P.C. Attorn rA f r Plaintiff A Law Firm En ag in De Collectioi By: David . Apothaker Dated: August 20, 2009 Our File No.: 205520 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff CACH, LLC VS. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, NO.: 09-4304 JONATHAN D SIMON Civil Action Defendant. AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. David J. Apothaker, being duly sworn according to law, deposes and says that I am the attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 885 TORWAY RD GARDNERS, PA 17324. We inquired with the web site of the Deft Boulevard, Suite 400, Arlington, VA 22209-2593, if Mary M. Snavely-Dixon, Director of the De indicated that the Defendant(s) is/are not in the mili David J. Apothaker Attorney for Plaintiff r Data Center, located at 1600 Wilson s) is/are in any branch of the military. Data Center has sent back our inquiry The above signed understands that the statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. D'e artIrirnt ifDeftra"? marl[ ''-4ut-r T'ata rtltm- 1V'lliltdl fit ab F'.rJl:.?rt Purs,!uxlt r? the =?t ?ICellieliibwrs 'ittil Relief A:_t .c, Last First Middle Beov Date Asti-e Duty Status Seii-ice?.Xgency Na><ne SII•.t- N .Tf N T IA2•T L, E a_: -n the mformation v-au haws fiunis;ed, the L?R2I?C does t ),,)t , . e -e,:, xm; information: t idicatmg that the mchvidual is rurrently on active div 7Tr?,rl _r;x- hnig the aif.?rrnati?.?r, ,iat,l t:.u is ,-fthe L'1q,artment ofDefense Ivl.,mp-:',verDato Center, Y"Is• rl -1-1 the 1nf<.rmatie'l1 that pr ,711e , thl 1i ;l c is the Current stati.ls 6417 the 111dividu al as tc all k"r ulrhes :'f the IUSilitars; y6ty, IM. 4A4 4??_ ,. IMar,, r:I :?thllr?•l'M- ?ir•al, L??ttY•ca-•r Dt$''jrt111eilt. '.•f Debenst - 1''?1cL 1??'.; '•°der Dzlt.d '-_?eafet It.-JU Aring.orl, V_ 2_`c:1.,9- 3 The Defense Idlanp:-wer Lata Center (DhE)C) is an orgarn?ation of the Department of Defense that mamtams the Defense EnroUr lent and Eligi aility Reporting 'System fDEEF:S'.t database which is the official sow-ce of data on eligibtil p' for mutaty rnledtcal art and ether elgit_ ilit"; systerns. The Department of Detense strongly supports the enforcement of the >ervicemernbers C'ivil Relief Act [-4)0 ?J' ?' • Appx § 51)1 Ct ell (SbA) {;f4rrneily he _ oldiers' and Salons' Civil Relief Act of 1940) DIvIL3t:,' has issued hundreds of thousands A "does that the mdraidual is cmently on active duty" responses. and has t :ptrienced a SmA err,:,r not pc >se s tuiy r1t;i7natiori ui iicatuig rate Il. flit er•euf the irl'.hvi Iua referenced above, gar any family member, fiiend, -.1 representative aszert. in air planner that the n1at?,1:Itlal .. >1'1 t dJuty. 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LL R l,trn'. ,''..R T12TG T -s certificate a as prc_inded based on a name and 'ocial Security: rnlmber (SSrT) ;`Tc ^idrd i_,y the requester. 'r< ri, ma an }rrone -,us narne :,r SSIT wvrll c ause art erroneous certificate to be provided ::?r ? ?r.* ??.DGDTQQSdHO • •205520 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY CACH, LLC VS. JONATHAN D SIMON COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-4304 To: JONATHAN D SIMON 885 TORWAY RD GARDNERS, PA 17324 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: August 03, 2009 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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 ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 BAR DAVID J. APOTHAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC A Law Firm Engaged in Debt Collection 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff Attorney ID #38423 O FILE'C w 2009 AUG 2 ]3): 2y, ?'? 1N a N" 1 t Cet? ?`17d tl7 TO: JONATHAN D SIMON 885 TORWAY RD GARDNERS, PA 17324 CACH, LLC Plaintiff, VS. JONATHAN D SIMON Defendant OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-4304 Civil Action NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. XX JUDGMENT BY DEFAULT JUDGMENT IN REPLEVIN JUDGMENT BY CONFESSION JUDGMENT FOR POSSESSION JUDGMENT ON AWARD OF ARBITRATORS JUDGMENT ON VERDICT JUDGMENT ON COURT FINDINGS JUDGMENT ON WRIT OF REVIVAL IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker, Esq. at this telephone number: 215-634-8920 9/ )7/U>