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Home My WebLink About09-6629Our File No.: 225109 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 ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. JEFFREY L FORSYTHE 650 BALTIMORE PIKE GARDNERS, PA 17324-8805 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY Cw? ?x NO.. 04- t?c?a9 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.: 225109 . 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 ATLANTIC CREDIT & FINANCE INC ASSIGNEE FROM HSBC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. JEFFREY L FORSYTHE 650 BALTIMORE PIKE GARDNERS, PA 17324-8805 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 4 9- (, 6,12 g &u• ? X CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are JEFFREY L FORSYTHE, an adult individual residing at 650 BALTIMORE PIKE GARDNERS, PA 17324-8805. 3. Plaintiff, ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC, is the Assignee and Successor in Interest of Account #5480420020621387; and said account was issued to Defendant(s) by HSBC, 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 $10,536.40. 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 $10,536.40 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASS C TES, P.C. Attorney for lai tiff A Law Firm Engage in ebt Collection BY: Dated: 9/30/2009 Our File No.: 225109 David J. Apothaker, Esquire 1 VERIFICATION t 6" b'nw () GmI , hereby states that I am kam-%CA MPS., MnAWr 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.SA 4904 relating to unworn falsification to authorities. OS1n1 QQ(7i? ?ILJ P1 DATE: ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC JEFFREY L FORSYTHE 650 BALTIMORE PIKE GARDNERS, PA 17324-8805 STATEMENT OF ACCOUNT Debtor's Name: JEFFREY L FORSYTHE Account Number: 5480420020621387 Original Creditor: HSBC Balance Due: $10,536.40 Our File No.: 225109 EXHIBIT "A" 0 OF TH-P pTr£C}T?Ry 2009 OCT -s PH 3: t 5 p ?` VNty t.?PvS YL??, !?n co t 5?8 i8 Io olz q4.o8 Sheriffs Office of Cumberland County R Thomas Kline ; err Sheriff ; Y Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor Atlantic Credit & Finance Inc. Assignee from HSBC Case Number vs. Jeffrey L. Forsythe 2009-6629 SHERIFF'S RETURN OF SERVICE 10/13/2009 03:54 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on October 13, 2009 at 1554 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jeffrey L. Forsythe, by making known unto Margaret Shindel, adult in charge at 650 Baltimore Pike Gardners, Cumberland County, Pennsylvania 17324 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $37.90 October 14, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF By YZ Deputy Sheriff Our File No.: 225109 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 ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC Plaintiff, vs. JEFFREY L FORSYTHE Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-6629 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCI ES, P.C. Attorneys for P n ff A Law Firm Engaged ' D t Collection By: David J. Apokiaker, Esquire Dated: October 15, 2009 FILED-OFFICE OF THE PPOT , TARP 2009 OCT 29 PM 3: 22 WUNTY PENNSYLVAN A