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Home My WebLink About09-8765Our Pile*No.: 231945 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 CACH, LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: N - $17105 0'iyll I&M JOHN THOMAS 613 SILVER SPRING RD MECHANICSBURG, PA 17050-2873 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.: 231945 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 CACH, LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. JOHN THOMAS 613 SILVER SPRING RD MECHANICSBURG, PA 17050-2873 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is CACH, LLC c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are JOHN THOMAS, an adult individual residing at 613 SILVER SPRING RD MECHANICSBURG, PA 17050-2873. 3. Plaintiff, CACH, LLC, is the Assignee and Successor in Interest of Account #5458000017114782; and said account was issued to Defendant(s) by METRIS, 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 $6,527.19. 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 $6,527.19 and requests this'Court award costs to the extent permitted by applicable law. APOTHAKER & ASSOQATES, P.C. Attorney f6r P: A Law Firm Engaged in BY: David J. Apothaker, Esquire Dated: 12/14/2009 Our File No.: 231945 Y ? 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 made subject to the penalties of 18 Pa.C.S.A. 4904 understands that the statements therein are unworn falsification to authorities. David P Apothaker, Esquire Attorney for Plaintiff DATE: 12/14/2009 JOHN THOMAS 613 SILVER SPRING RD MECHANICSBURG, PA 17050-2873 CACH,LLC STATEMENT OF ACCOUNT Debtor's Name: Account Number: Original Creditor: Balance Due: Our File No.: 231945 JOHN THOMAS 5458000017114782 METRIS $6,527.19 EXHIBIT "A" A Y 10;19 U-- t, 21 21 2 +Qa. oc, Po A-rN &* Iloa'II wrt awact SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson FI~.ED-UFr=iCE ;JF 7ElE I~OT~~J!~(?TARY Sheriff , ., - 'S~'~A _ 1.7,.i Jody s smith ~ ~ 2010 JAN -8 At9 9~ 04 Chief Deputy Edward L Schorpp (',U{yl~~` ~~~l,j (;()U~1('(Y Solicitor I~~I~i~~'~ Cach, LLC vs. John R. Thomas Case Number 2009-8765 SHERIFF'S RETURN OF SERVICE 01/05/2010 08:51 PM -Michael Garrick, Deputy Sheriff, who being duly sworn according to law, states that on January 5, 2010 at 2051 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: John R. Thomas, by making known unto himself personally, at 613 Silver Spring Road, Mechanicsburg, Cumberland County, Pennsylvania 17050 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $37.00 January 06, 2010 SO ANSWERS, (l~(NVNY R ANDERSON, SHERIFF ..puty Sheriff Our File No.: 231945 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 CACH, LLC Plaintiff, vs. JOHN THOMAS Defendant. t}F TNF~~E ,. ~ ~~J7AR'~' ZDIO ~~~~ ~ $ €~~~~ ~~~ ~ 2 Cam!"ilr} ~:''~ COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 09-8765 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & OCIATES, P.C. Attorne for laintiff A Law Firm E aged n Debt Collection By: David J. othaker, Esquire Dated: 3/9/2010