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Home My WebLink About09-7627 Our File No.: 225427 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. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Oq - r7&9-1 CCORY L WHITMOYER 57 CIRCLE DR CAMP HILL, PA 17011-2609 Defendant. 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.: 225427 APOTHAAKER & 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. CORY L WHITMOYER 57 CIRCLE DR CAMP HILL, PA 17011-2609 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0q IG ;-?? C,uxP ?t-? 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 GORY L WHITMOYER, an adult individual residing at 57 CIRCLE DR CAMP HILL, PA 17011-2609. 3. Plaintiff, ADVANTAGE ASSETS II, INC., is the Assignee and Successor in Interest of Account #5049940164615212; and said account was issued to Defendant(s) by SEARS, 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 $1,141.39. 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. 01 WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $1,141.39 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. A Law Firm ErfizageMin Debt Collection BY: Dated: 10/28/2009 id J. 611at3faker, Esquire Our File No.: 225427 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 fo *worn falsification to authorities. David J. Ap ak , squire Attorney Plaintiff DATE: 10/28/2009 ADVANTAGE ASSETS II, INC. CORY L WHITMOYER 57 CIRCLE DR CAMP HILL, PA 17011-2609 STATEMENT OF ACCOUNT Debtor's Name: CORY L WHITMOYER Account Number: 5049940164615212 Original Creditor: SEARS Balance Due: $1,141.39 Our File No.: 225427 EXHIBIT "A" 0 FL O T( "= l 2H9NOV -4 Ftl 2: 55 Cl,.?!'f ? ' 'r ?T1! *18.5o PD A TrY Ck. 13`745a R a,33oo5 R Thomas Kline Sheriff Ronny R Anderson Chief Deputy SHERIFF'S OFFICE OF CUMBERLAND COUNTY -- --, ~ . „t :, .. t.uii~, Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor f -, . ~-... ,,j~,t, .. ~, . Advantage Assetts II, Inc. vs. Cory L. Whitmoyer Case Number 2009-7627 SHERIFF'S RETURN OF SERVICE 11/06/2009 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: Cory L. Whitmoyer, but was unable to locate him in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the defendant Cory L. Whitmoyer. Current resident of 57 Circle Drive Camp Hill, PA 17011 advised Deputy's the defendant was removed from this address two months ago, his mail is still delivered to this address and he may have moved out of state. An exact address is not available. /7 SHERIFF COST: $x-!b~!~O SO November 06, 2009 ~,,,~`~.THfbMAS KLINE, SHERIFF