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Home My WebLink About09-5742 Our File No.: 211817 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. MELVIN E MOHR & JUDITH R MOHR 8 CHESTNUT RIDGE RD GARDNERS, PA 17324-9064 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0'3 - 5 7 y aZ Ct,?J- 7-,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 T 1 Our File No.: 211817 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. MELVIN E MOHR & JUDITH R MOHR 8 CHESTNUT RIDGE RD GARDNERS, PA 17324-9064 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0'?- 5 7Y,2 ? 7-e, 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 MELVIN E MOHR & JUDITH R MOHR, an adult individual residing at 8 CHESTNUT RIDGE RD GARDNERS, PA 17324-9064. 3. Plaintiff, CACH, LLC, is the Assignee and Successor in Interest of Account #4264298996614908; and said account was issued to Defendant(s) by MARYLAND NATIONAL BANK, 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 $7,000.52. 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 $7,000.52 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & A O IATES, P.C. Attorney fed Pl ntiff A Law Firm Eniza in ebt CoIW tint Dated: 8/14/2009 BY: David J. Apothaker, Esquire Our File No.: 211817 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 relatipl to unworn falsification to authorities. David J\Apothaker, Esquire Atto y for Plaintiff DATE: 8/14/2009 CACH, LLC MELVIN E MOHR & JUDITH R MOHR 8 CHESTNUT RIDGE RD GARDNERS, PA 17324-9064 STATEMENT OF ACCOUNT Debtor's Name: MELVIN E MOHR & JUDITH R MOHR Account Number: 4264298996614908 Original Creditor: MARYLAND NATIONAL BANK, N.A. Balance Due: $7,000.52 Our File No.: 211817 EXHIBIT "A" ALE{;--!,! FK-1 OF TNC Pw=J°H( !NARY ZCL" 9 Au0, 19 Per : 0' 9 c.x- 1y?!I7 lC?ac. )..29,g3r Sheriffs Office of Cumberland County R Thomas Kline Sheri Ronny R Anderson Chief Deputy ????ttitr at ?uuiLPC(??f? OF=ICE CF T''4C ERIFF OF T11: P"'I" Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor Cach, LLC vs. Judith R. Mohr 2009 SEP - I i it 9:40 p ? 4 ?! Case Number 2009-5742 SHERIFF'S RETURN OF SERVICE 08/29/2009 11:45 AM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 29, 2009 at 1145 hours, he served a true copy of the within, Complaint and Notice upon the within named defendant, to wit: Judith R. Mohr, by making known unto Melvin Mohr, husband of defendant at 96 W. Pomfret Street #C 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. 08/2912009 11:45 AM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 29, 2009 at 1145 hours, he served a true copy of the within, Complaint and Notice upon the within named defendant, to wit: Melvin E. Mohr, by making known unto himself personally, at 96 W. Pomfret Street #C 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: $59.30 SO ANSWERS, ?a6LWW August 31, 2009 R THOMAS KLINE, SHERIFF By Deputy Sheriff Our File No.: 211817 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 CACH, LLC vs. Plaintiff, MELVIN E MOHR & JUDITH R MOHR Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-5742 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASS ATES, P.C. Attorneys fo linetbt tiff A Law Firm Engag Collection By: David J. Apothaker, Esquire Dated: 10/2/2009 I s , ._ F GARY 2009 OCT 16 PH 3: 36