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Home My WebLink About09-5762J ? Our File No.: 215905 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. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 09 - ST 0,t,4-Fern, BRIGHT H ZENGE 605 BRENTWATER RD CAMP HILL, PA 17011-1502 Defendant. 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.: 215905 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. BRIGHT H ZENGE 605 BRENTWATER RD CAMP HILL, PA 17011-1502 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Q c! - 6_761 Ca. -rd 7[t-' 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 BRIGHT H ZENGE, an adult individual residing at 605 BRENTWATER RD CAMP HILL, PA 17011-1502. 3. Plaintiff, CACH, LLC, is the Assignee and Successor in Interest of Account #74973996267612; 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 $5,197.70. 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 $5,197.70 and requests this Courtaward costs to the extent permitted by applicable law. APOTHAKER & ASS IATES, P.C. Attorney fo 1 'tiff A Law Firm Enaaa in ebt Collection BY: Dated: 8/12/2009 David J. Our File No.: 215905 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 uns4alsification to authorities. David J. Apoth'ker, Y- Attorney for ainti DATE: 8/12/2009 CACH, LLC BRIGHT H ZENGE 605 BRENTWATER RD CAMP HILL, PA 17011-1502 STATEMENT OF ACCOUNT Debtor's Name: BRIGHT H ZENGE Account Number: 74973996267612 Original Creditor: MARYLAND NATIONAL BANK, N.A. Balance Due: $5,197.70 Our File No.: 215905 EXHIBIT "A" OF THE 2099 AUG 20 A I I: 4 u *'I8. 5o p o ATT4 act 141.oqoq e aag 517 Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy 0MCE OF THE SHERIFF OF THE ""7 ARY Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor Cach, LLC VS. Bright H. Zenge 2009 AUG 31 PH 3. 35 CU ti`s Case Number 2009-5762 SHERIFF'S RETURN OF SERVICE 08/27/2009 07:32 PM - Noah Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 27, 2009 at 1932 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Bright H. Zenge, by making known unto himself personally, at 605 Brentwater Road 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 August 28, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF 13y Deputy Sheriff Our File No.: 215905 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 Plaintiff, VS. BRIGHT H ZENGE Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-5762 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys for 'ntiff A Law Firm Enaa m ebt Collection By: David J. Apothaker, Esquire Dated: 10/14/2009 RL9)-Of-rlC E OF 1W ?1 O VARY 2009 OCT 27 AM 9* 04 Ct1M r utm PENINSVANtA