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Home My WebLink About09-7331Qur File No.: 219130 ,APOTHAKER & ASSOCIATES, P.C. BY: David, J. Apothaker, Esquire, Esq. Attorney I..#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff LTD ACQUISITIONS, LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. DOUGLAS A LYNN 119 E PORTLAND ST MECHANICSBURG, PA 17055-3333 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: N- 1733I Livil lurk 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.: 219130 ,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 LTD ACQUISITIONS, LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. DOUGLAS A LYNN 119 E PORTLAND ST MECHANICSBURG, PA 17055-3333 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: D 9 - 73 3 C".1-1 e ? CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is LTD ACQUISITIONS, LLC c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are DOUGLAS A LYNN, an adult individual residing at 119 E PORTLAND ST MECHANICSBURG, PA 17055-3333. 3. Plaintiff, LTD ACQUISITIONS, LLC, is the Assignee and Successor in Interest of Account #4104130023881081; and said account was issued to Defendant(s) by CHASE BANK USA 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 $4,955.88. 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 $4,955.88 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & S IATES, P Attorney or Pl 'tiff lec, A Law Firm Enga ed in ebt C BY: Dated: 10/15/2009 David J. Ap* r, Esquire Our File No.: 219130 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 to unworn falsification to authorities. David Apbtfiaker, Esquire Att ev for Plaintiff DATE: 10/15/2009 DOUGLAS A LYNN LTD ACQUISITIONS, LLC 119 E PORTLAND ST MECHANICSBURG, PA 17055-3333 STATEMENT OF ACCOUNT Debtor's Name: DOUGLAS A LYNN Account Number: 4104130023881081 Original Creditor: CHASE BANK USA N.A. Balance Due: $4,955.88 Our File No.: 219130 EXHIBIT "A" v OF " O car A-lN # h8.50 C,?,? ?s5 I $ 3 a;3a,5 t 8 SHERIFF'S OFFICE OF CUMBERLAND COUNTY FEi C`~` R Thomas Kline Sheriff Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor LTD Acquisitions, LLC vs. Douglas A. Lynn Case Number 2009-7331 SHERIFF'S RETURN OF SERVICE 11/05/2009 Michael Garrick, Deputy Sheriff, who being duly sworn according to law, states that on November 5, 2009 at 1533 hours, he was unable to serve a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Douglas A. Lynn. An adult male answered the door but would not reopen the door to accept service. SHERIFF COST: $37.00 November 06, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF ~--'/~ put Sheri ~q.~~`1l4 t~ \-tl!idiar~.f~rr~ .al C:~ .- ~l:i'~ _ _ .-i~a 1 David (D. Bue(C Prothonotary KirkS. Sohonage, ESQ Soricitor knee X Simpson 151 Deputy Prothonotary Irene E. W orrow 2"d Deputy Prothonotary Office of the Prothonotary Cumber(and County, Pennsylvania 0916 "w_ CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 30TH DAY OF OCTOBER, 2012, AFTER MAILING NOTICE OF INTENTION TO PROCEED AND RECEIVING NO RESPONSE -THE ABOVE CASE IS HEREBY TERMINATED WITH PREJUDICE IN ACCORDANCE WITH PA R.C.P. 230.2. BY THE COURT, DAVID D. BUELL PROTHONOTARY Fax (717) 240-6573