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Home My WebLink About09-5764Our File No.: 215798 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. ELIZABETH SCHMICK 204 MAPLE AVE CAMP HILL, PA 17011-4122 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: OR- 571oy Ctvil lea'm 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 O File No.: 215798 APOTHAKER & ASSOCIATES; F.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. ELIZABETH SCHMICK 204 MAPLE AVE CAMP HILL, PA 17011-4122 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 4 - T 7 (, `f ?uri-? ?? ?,??. 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 ELIZABETH SCHMICK, an adult individual residing at 204 MAPLE AVE CAMP HILL, PA 17011-4122. 3. Plaintiff, CACH, LLC, is the Assignee and Successor in Interest of Account #5490357999136856; 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 $21,535.38. 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 $21,535.38 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & Attorney A Law Firm Enaac Dated: 8/12/2009 BY: David J IkTES, P.C. Debt , Esquire Our File No.: 215798 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 rel in o unworn falsification to authorities. David J. Aptothaker, Esquire Attorney for Plaintiff DATE: 8/12/2009 ELIZABETH SCHMICK 204 MAPLE AVE CACH, LLC CAMP HILL, PA 17011-4122 STATEMENT OF ACCOUNT Debtor's Name: ELIZABETH SCHMICK Account Number: 5490357999136856 Original Creditor: MARYLAND NATIONAL BANK, N.A. Balance Due: $21,535.38 Our File No.: 215798 EXHIBIT "A" 2u 03 a, UG 42 0 AI"i i d= 4 7 'UN TY -*'78.510 PD ATTq 14 66 S!S ? aagsl R Sheriffs Office of Cumberland County R Thomas Kline Sheriff Ronny R Anderson Chief Deputy -' Jody S Smith Civil Process Sergeant OFF,CE C7 T-: '-ERIFF Edward L Schorpp Solicitor AlED -)? E?-, ,7- i 2OB AUG 20 PH F2= 50 kj? Cach, LLC vs. Elizabeth Schmick Case Number 2009-5764 SHERIFF'S RETURN OF SERVICE 08/24/2009 06:30 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on August 24, 2009 at 1830 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Elizabeth Schmick, by making known unto herself personally, at 204 Maple Avenue Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.50 August 25, 2009 SO ANSWERS, 4 -r < 4 . - AQ omwoung -W R THOMAS KLINE, SH K FF By ty S eri Our File No.: 215798 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. ELIZABETH SCHMICK Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-5764 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys for P mtiff A Law Firm Engaged ebt Collection By: David J Dated: August 27, 2009 OF THE 2099 SEE -3 F612: S3 i l:' F