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Home My WebLink About09-5113/ .. Our File No.: 215090 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 GE MONEY BANK c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. TAMMY BENNETT 31 NATHAN DR ENOLA, PA 17025-2676 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 09 - N13 0'w; t (erM 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 Otir File No.: 215090 , 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 GE MONEY BANK c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. TAMMY BENNETT 31 NATHAN DR ENOLA, PA 17025-2676 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is GE MONEY BANK c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are TAMMY BENNETT, an adult individual residing at 31 NATHAN DR ENOLA, PA 17025-2676. 3. At the special instance and request of Defendant, Plaintiff, GE MONEY BANK, issued to Defendant(s), Account #6032201498995722. 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 $3,658.31. 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 $3,658.31 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOC TES, P.C. Attorney for Pl ' ti A Law Firm Engaged in j t Collection BY: David J. Anothaker s Dated: 7/17/2009 Our File No.: 215090 VERIFICATION David J. Anothaker Esquire Esq.. 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. 490,4?rejating to unworn falsification to authorities. David J. ApA?r, Esquire Attorney for Plaintiff DATE: 7/17/2009 GE MONEY BANK TAMMY BENNETT 31 NATHAN DR ENOLA, PA 17025-2676 STATEMENT OF ACCOUNT Debtor's Name: TAMMY BENNETT Account Number: 6032201498995722 Balance Due: $3,658.31 Our File No.: 215090 EXHIBIT "A" Q FLED-0 . OF Tj I - r ,*,'01TARY 20109 'JIUL 27 Pli 2: - 3 CUM, e P?8 S. So PQ Ar-/ Ge,`r" 143a.31 p-T* aas q go Sheriffs Office of Cumberland County R Thomas Kline Sheri ?4??tp bt ?uaaber,??4 OFFICE OF THE $HERIFF 1 1 X11, Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor GE Money Bank VS. Tammy Bennett 2u0 3 }iU5 .12 Ar] S. J Y Case Number 2009-5113 SHERIFF'S RETURN OF SERVICE 08/05/2009 06:22 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 5, 2009 at 1822 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Tammy Bennett, by making known unto herself personally, defendant at 31 Nathan Drive Enola, Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.50 SO ANSWERS, 4 AN 49!!?4 August 06, 2009 R THOMAS KLINE, SHERIFF /?Va puty Sheriff Our File No.: 215090 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff GE MONEY BANK VS. TAMMY BENNETT Plaintiff, ) Defendant. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-5113 CIVIL TERM PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. By: APOTHAKER & ASSOCIATES, P.C. Attorneys for P?ff A Law Firm Engaged i e Collection David J Dated: September 29, 2009 FiLEU-Ori-1 CE OF VFE PP P ,"WOTARY 2009 OCT -8 PH 2: 28