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HomeMy WebLinkAbout09-7624Ohr File No.: 225585 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 ADVANTAGE ASSETS II, INC. c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. BRIAN J GINTER 321 W MAIN ST Apt 1 MECHANICSBURG, PA 17055 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: OQ - 7(001 0,;-,;1Tem 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 Char File No.: 225585 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 ADVANTAGE ASSETS II, INC. c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. BRIAN J GINTER 321 W MAIN ST Apt 1 MECHANICSBURG, PA 17055 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: a 9- 7G a V ?cucx U1.1- CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is ADVANTAGE ASSETS II, INC. c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are BRIAN J GINTER, an adult individual residing at 321 W MAIN ST Apt 1 MECHANICSBURG, PA 17055. 3. Plaintiff, ADVANTAGE ASSETS II, INC., is the Assignee and Successor in Interest of Account #6035320104454184; and said account was issued to Defendant(s) by THD ELECTRONICS, 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 $3,115.64. 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 $3,115.64 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & Attorney A Law Firm Enizat RTES, P.C. bt Collection BY: David J Dated: 10/28/2009 Our File No.: 225585 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 tri sworn falsification to authorities. David J. Ap a1 sqi Attorney for Plaintiff DATE: 10/28/2009 a BRIAN J GINTER ADVANTAGE ASSETS II, INC. 321 W MAIN ST Apt 1 MECHANICSBURG, PA 17055 STATEMENT OF ACCOUNT Debtor's Name: BRIAN J GINTER Account Number: 6035320104454184 Original Creditor: THD ELECTRONICS Balance Due: $3,115.64 Our File No.: 225585 EXHIBIT "A" (Lc, r:, r NARY 2009 NOV -4 Pl 2: 54 CL'?d -'UNT' , L'ANIA ?18.W Po NTN at* 159 46 G a*,*woo3 SHERIFF'S OFFICE OF CUMBERLAND COUNTY R Thomas Kline Sheriff .~yt~~t}v ~1_ "~trml'trr Ronny R Anderson V ~~~'0 Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor Advantage Assetts II, Inc. vs. Brian J. Ginter F!E t=i~-~~!~~~,~ r~ ~r -~'L_r i '~jnr7Y 2Gu~ C~i~ - ! ~~{ ^~ ~ 2 -,; ~~~~-. . ~'ta•~;~~~ Case Number 2009-7624 SHERIFF'S RETURN OF SERVICE 11/30!2009 R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a diligent search and inquiry for the within named defendant to wit: Brian J. Ginter, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Brian J. Ginter. Nicole Baker current resident of 321 W. Main Street Apt. 1 Mechanicsburg, PA 17055 advised Deputies Brian J. Ginter is currently located at Dauphin County Work Release Center 919 Gibson Blvd., Steelton, PA 17113. SHERIFF COST: $60.00 November 30, 2009 David 1D. Bueff Prothonotary 2,irkS. Sohonage, ESQ, Solicitor c F Ci. 7750 4?§nee X Simpson 1" Deputy Prothonotary Irene E. W orrow 2"d Deputy Prothonotary Office of the Prothonotary Cumberfand County, 1Pennsy(vania • %;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 /717) 240-F19 S • "Fl x- /717)