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Home My WebLink About09-6813Ouf File No.: 224378 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. FRANCIS DERENZO 711 LONGS GAP RD CARLISLE, PA 17013-8527 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Oq - 60813 Civ?? Terw, 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.: 224378 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. FRANCIS DERENZO 711 LONGS GAP RD CARLISLE, PA 17013-8527 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 FRANCIS DERENZO, an adult individual residing at 711 LONGS GAP RD CARLISLE, PA 17013-8527. 3. At the special instance and request of Defendant, Plaintiff, GE MONEY BANK, issued to Defendant(s), Account #5466801038824600. 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 $3,905.33. 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 $3,905.33 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSO TES, P.C. Attorney for PI tiff A Law Firm Enaa0ed i Debt Collection BY: David J. Apother, Esquire Dated: 10/7/2009 Our File No.: 224378 VERIFICATION David J Apothaker 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, The undersigned understands that the statements therein are made subject to the penalties of 18 relating to unsworn falsification to authorities. David J. Atothaker, Esquire Attorney for Plaintiff DATE: 10/7/2009 GE MONEY BANK FRANCIS DERENZO 711 LONGS GAP RD CARLISLE, PA 17013-8527 STATEMENT OF ACCOUNT Debtor's Name: FRANCIS DERENZO Account Number: 5466801038824600 Balance Due: $3,905.33 Our File No.: 224378 EXHIBIT "A" Z?v9 On 13 ?11 3? 01 .*78.5C) PD AM cel ts4 tts W* (231 8,q5 Sheriffs Office of Cumberland County _ __ _,~. R Thomas Kline ~I ' '~.~ ' L„«_?~ Sheriff ',~ 1 Ronny R Anderson ~°v~~s~~ ~t ~'""t,~'rtr~~~ .z~~~ Chief Deputy >'~'.;~3 -~ Jody S Smith ~ ~ ,, , Civil Process Sergeant ^F- , ~ ~ ~ - •~.-~~~~ '~""'~ Edward L Schorpp Solicitor GE Money Bank vs. Case Number Francis Derenzo 2009-6813 SHERIFF'S RETURN OF SERVICE 10/19/2009 03:10 PM -Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on October 19, 2009 at 1510 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Francis Derenzo, by making known unto himself personally, at 711 Longs Gap Road 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: $33.40 October 20, 2009 SO ANSWERS, ~~ ~~.I~~~-I R THOMAS KLINE, SHERIFF gY Deputy eriff i