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Home My WebLink About10-1194Our File No.: 246630 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire 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. SHAWN P KLEEMAN 125 SOVEREIGN DR CARLISLE, PA 17015-7312 Defendant. FILED ,w -ICE 2010 FEB 22 Ah 11: 51 VLJB't{ F 'ITY COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: IC - 1191 NOTICE N I Trm 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 061. oo PD Al"M co 1,11069 V*.137 953 1 1% Our File No.: 246630 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire 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. SHAWN P KLEEMAN 125 SOVEREIGN DR CARLISLE, PA 17015-7312 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. Gw, 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 SHAWN P KLEEMAN, an adult individual residing at 125 SOVEREIGN DR CARLISLE, PA 17015-7312. 3. Plaintiff, ADVANTAGE ASSETS II, INC., is the Assignee and Successor in Interest of Account #6035320226846572; and said account was issued to Defendant(s) by CITIBANK/THD, 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 $1,973.40. 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 $1,973.40 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & A CIATES, P.C. Attorney r P 'ntiff A Law Firm EnV d ' Debt C?ecfio BY: David J. Apotlaker, Esquire Dated: 2/16/2010 Our File No.: 246630 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 uns orn falsification to authorities. David J. Apothaker, Esquire Attorney for Plaintiff DATE: 2/16/2010 ADVANTAGE ASSETS II, INC. SHAWN P KLEEMAN 125 SOVEREIGN DR CARLISLE, PA 17015-7312 STATEMENT OF ACCOUNT Debtor's Name: SHAWN P KLEEMAN Account Number: 6035320226846572 Original Creditor: CITIBANK/THD Balance Due: $1,973.40 Our File No.: 246630 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff ??t atuir?b?r? ,?Ftt_E, c ThE S-ERIFF FllEO-O???E OF THE FIR0 T H" OT?Y Jody S Smith Chief Deputy Edward L Schorpp Solicitor 2010 MAR -8 FM 12: 54 CUr_` i DENY Advantage Assets il, Inc. vs. Shawn P. Kleeman Case Number 2010-1194 SHERIFF'S RETURN OF SERVICE 02/23/2010 07:31 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on February 23 2010 at 1931 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Shawn P. Kleeman, by making known unto himself personally, at 125 Sovereign Drive, 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 February 25, 2010 SO ANSWE RON Y ANDERSON, SHERIFF By Deput Sherif iC% GountpSUIte She-ft, Teleosoft. Inc. Our File No.: 246630 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800)672-0215 Attorney for Plaintiff ADVANTAGE ASSETS II, INC. vs. Plaintiff SHAWN P KLEEMAN Defendant - -~-~_~r- - . ~ i r~, `~~ ~r:,:v: ._ : i . ;- COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-1194 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, SHAWN P KLEEMAN, in the default of an Answer, in the amount of $1,988.10 computed as follows: Amount claimed in complaint: $ 1,973.40 Less: Amount Paid: ( 0.00} Plus: Interest from February 16, 2010 to Apri15, 2010 at the legal interest rate of 6.00% per annum 14.70 Attorney fees 0.00 TOTAL $ 1,988.10 J I certify that Defendant, SHAWN P KLEEMAN,'la t known address is 125 SOVEREIGN DR CARLISLE, PA 17015-7312. David J. Apothaker, Esq. Attorney for Plaintiff Dated: April 5, 2010 ~l4•0o PQ AT'M erg l~~as~ ~Jnk~, I.~a.~,led OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: SHAWN P KLEEMAN 125 SOVEREIGN DR CARLISLE, PA 17015-7312 ADVANTAGE ASSETS II, INC. Plaintiff vs. SHAWN P KLEEMAN Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-1194 Civil Action NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated below. XX JUDGMENT BY DEFAULT JUDGMENT IN REPLEVIN JUDGMENT BY CONFESSION JUDGMENT FOR POSSESSION JUDGMENT ON AWARD OF ARBITRATORS JUDGMENT ON VERDICT JUDGMENT ON COURT FINDINGS JUDGMENT ON WRIT OF REVIVAL IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker, Esc at this telephone number: 800-672-0215 \~ ~'f/!S~ 0 Our File No.: 246630 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff ADVANTAGE ASSETS II,1NC. vs. Plaintiff SHAWN P KLEEMAN Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-1194 Civil Action CERTIFICATION PURSUANT TO RULE 237.1 Pursuant to PA Rule Civil Procedure 237.1, I certify that a copy of the NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT has been sent to the Defendant or the Attorney of Record. I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. David J. Apot er, Esq. Attorney for Plat 'ff Dated: Apri15, 2010 Our File No.: 246630 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800)672-0215 Attorney for Plaintiff ADVANTAGE ASSETS II,1NC. vs. Plaintiff SHAWN P KLEEMAN Defendant Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA SS. COUNTY OF CUMBERLAND David J. Apothaker, being duly sworn according to law, deposes and says that I am the attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 125 SOVEREIGN DR CARLISLE, PA 17015-7312. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-25~, if the Defendant(s) is/are in any branch of the military. / I Mary M. Snavely-Dixon, Director of the Def se anpowe ata Center has sent back our inquiry indicated that the Defendant(s) is/are not i the ilit David J. Apothaker, Esq. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 10-1194 I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. ~` ° Drpaatmtstt of Drfinsc ~iaapox=s I?ata Cesker ARt-0t-:414 48:14:44 '.Y ~ ~ s~.~t ~~~ ~~ iiriei'Act •'~' Lnt FrrsNiii~e Besia Date Acti~•e Doty 5oaa Aroivr Dw Ead Date r3erttre \aare .~eucp• KI.~Lt~~i . SHARD P Based oa the itd'atufasioa you lfa~x fiatushed. the D~iDC does net possess tmy iafrxmatiars mating fire irs~siehral sue. Utfon scarchipg the isffarffr~oss data beaks of t&r Drpaift e>f Defense 113at~artr Data Cemr, based on the iafermation that ?roe prrn'ded, the abme rs the svtrerx states the iadiwrhasd as to a~ brarn:lsrs of fix >~taitartrsed Sac~ts (Araay, Ikasg•, ~larirstt C«ps. 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Aim Der; stereo also ~pliea to a ~nEaemed Service sacmbet who h ffia a day commirsir>acd a~cer of the L'.S Pssblic Hetsltts Sm~e a Ase tYS#ioeel Ocesiic aEfd Atrrrosplreric Admirestrmiors t~O.~A C'a~ossiaoed Caaps~ Sat a gesiod of mare i~ . 4 coasecuPise lags. Cc+-r+ttgc t nder rJrs S4'R.91 ir.8rarder in So~ara Cates Canxrase smiler the SCRA g braadQ in same cases cal ioclo3es same categories of pasorss as attire drrtp for purposes ~' tlr S CRA nfio avoid ant be rrlaortrd as ~ Artist Dntp utfdrr rtes cett~cntr. S3rurj tmsrs orders arc amrrsded to cit:rad the period ~sctivc duty, a3sieh vvonld cateru! SCR,f, prc>trctimc. 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Prrnid~y an eacmeaas ~c err SS'e w-iH cause an errarbeccus crrti$cate is be 1xa~id~rd Aeport IDHSBA'+f"1fPS 246630 OFFICE OF THE PROTHONOTARY ' ~ ~ ' COURT OF COMMON PLEAS CUMBERLAND COUNTY ADVANTAGE ASSETS II, INC. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) SHAWN P KLEEMAN } NO. 10-1194 To: SHAWN P KLEEMAN 125 SOVEREIGN DR CARLISLE, PA 17015-7312 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: March 19, 2010 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. IF YOU CANNOT AFFORD TO HIlZE 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 ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 BAR D VID J. APOTHAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC A Law Firm Engaged in Debt Collection 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800)672-0215 Attorney for Plaintiff Attorney ID #38423 Our File No.: 246630 h R0TH0IN 0t€7,;, ADVANTAGE ASSETS I1, INC. UBERLAND HE COURT OF COMMON PLEAS OF Plaintiff 13 OCT, 29 AH I I' 0 COUNTY, CUMBERLAND COUNTY ENNSYLVANIA vs. SHAWN P KLEEMAN PENNSYLVANIA 10-1194 Defendant(s) PRAECIPE FOR WRIT OF EXECUTION To the Prothonotary: Issue a Writ of Execution in the above matter, (1) directed to the Sheriff of CUMBERLAND County; (2) against SHAWN P KLEEMAN, defendant(s); and (3) against MEMBERS 1 ST FCU 5000 LOUISE DRIVE MECHANICSBURG, PA 17055, Garnishee(s); (4) and index this writ in the judgment index (a) against SHAWN P KLEEMAN, defendant(s), and (b) against MEMBERS 1'ST FCU 5000 LOUISE DRIVE MECHANICSBURG,PA 17055, as Garnishee(s), as a lis pendens against the real property of the defendant(s) in the name of Garnishee(s)as follows: Bank Attachment Only - All assets and accounts. including, but not limited to, bank accounts, brokerage firm accounts, stocks, cd's, insurance, safety deposit boxes, etc. (5) Amount Due $1988.10 Interest from April 15, 2010 $386.54 Minus Payments made -$ Plus Costs $193.00 Total $2567.64 C�2)> David J. Apothaker. Esquire '4 z"-F Attorney for Plaintiff(,- �q . D0 Lk t . S6 Qw�q U C� WRIT OF EXECUTION and/or ATTACHMENT COMMONWEALTH OF PENNSYLVANIA) NO 2010-1194 Civil COUNTY OF CUMBERLAND) CIVIL ACTION—LAW TO THE SHERIFF OF CUMBERLAND COUNTY: To satisfy the debt, interest and costs due ADVANTAGE ASSETS,II, INC. Plaintiff(s) From SHAWN P. KLEEMAN,28 PINE HILL AVENUE,MECHANICSBURG,PA 17050 (1) You are directed to levy upon the property of the defendant(s)and to sell You are also directed to attach the property of the defendant(s)not levied upon in the possession of GARNISHEES)as follows: MEMBERS 1sT FCU,5000 LOUISE DRIVE,MECHANICSBURG,PA 17055-ALL ASSETS AND ACCOUNTS,INCLUDING,BUT NOT LIMITED TO,BANK ACCOUNTS,BROKERAGE FIRM ACCOUNTS,STOCKS,CD'S,INSURANCE,SAFETY DEPOSIT BOXES,ETC. and to notify the garnishee(s)that: (a) an attachment has been issued; (b)the garnishee(s) is enjoined from paying any debt to or for the account of the defendant(s) and from delivering any property of the defendant(s)or otherwise disposing thereof, (2) If property of the defendant(s)not levied upon an subject to attachment is found in the possession of anyone other than a named garnishee,you are directed to notify him/her that he/she has been added as a garnishee and is enjoined as above stated. Amount Due$1,988.10 Plaintiff Paid$ Interest FROM APRIL 15,2010-$386.54 Attorney's Comm. % Law Library$.50 Attorney Paid$168.40 Due Prothonotary$2.25 Other Costs$193.00 Date: 10/29/2013 I David D. Buell, Prothonotary Deputy REQUESTING PARTY: Name : DAVID J APOTHAKER,ESQUIRE Address: APOTHAKER& ASSOCIATES,P.C. 520 FELLOWSHIP ROAD C306 MT.LAUREL,NJ 08054 Attorney for: PLAINTIFF Telephone: 1-800-672-0215 Supreme Court ID No. SHERIFF'S OFFICE OF CUMBERLAND COUNTY Ronny R Anderson -0 c t I C f Sheriff :.. TI'H {'p 100 if-� ¢ �� i"I 1� �1�LJ i M1'\��t^4 E t 1 Jody S Smith Chief Deputy ' 2613 NOV 14 AM 9: 3 Richard W Stewart .,: : Solicitor O�.��CE OFT��E$t:EPlFF � �H�1~�LA�I�� COMITY PENNSYLVANIA Advantage Assets II, Inc. Case Number vs. Shawn P. Kleeman 2010-1194 SHERIFF'S RETURN OF SERVICE 11/07/2013 01:05 PM-William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels,rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Members 1 st Federal Credit Union, 321 York Road, Carlisle, PA 17013, Cumberland County, by handing to Melisa Hollis, Manager, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on November 13, 201 to Shawn P. Kleeman at 28 Pine Hill Avenue, Mechaniscburg, PA 17050. `�--_'_ I LIAM CLINE, DEPUTY SO ANSWERS, November 12, 2013 RON R ANDERSON, SHERIFF (c)Courty&"'e Shorif!.TeleosoP,.Inc. Our File No.: 246630 ,;7i 3 ? v APOTHAKER&ASSOCIATES, P.C. By: David J. Apothaker, Esquire `' ` j � C8U? s�,520 Fellowship Road C306 r"l_ ;'( PO Box 5496 Mount Laurel,NJ 08054 (800) 672-0215 Attorneys for Plaintiff ) ADVANTAGE ASSETS II, INC. ) COURT OF COMMON PLEAS OF ) CUMBERLAND COUNTY Plaintiff ) vs. ) ) NO.: 10-1194 SHAWN P KLEEMAN ) ) Civil Action Defendant ) ) MEMBERS 1 ST FCU ) ) Garnishee ) ) PRAECIPE TO DISSOLVE ATTACHMENT EXECUTION TO THE PROTHONOTARY: Kindly mark the attachment against the Garnishee, ME : I RS 1 ST FCU, dissolved. k David J. pothaker, Esquire Attorney for Plaintiff atd, 9,stPda i' c ,4 gacosa _ ci Rdy Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY OFF CE QF TI-,, , V°RERIF THE ?ROTH 1,1 .>111 JUN I6 PH 2: 314 CUMBERLAND COUNTY PENNSYLVANIA Advantage Assets II, Inc. vs. Shawn P. Kleeman Case Number 2010-1194 SHERIFF'S RETURN OF SERVICE 11/07/2013 01:05 PM - William Cline, Deputy, who being duly sworn according to law, attached as herein commanded all goods, chattels, rights, debts, credits, and monies of the Defendant, in the hands, possession, or control of the within named garnishee, Members 1st Federal Credit Union, 321 York Road, Carlisle, PA 17013, Cumberland County, by handing to Melisa Hollis, Manager, personally three copies of interrogatories together with three true and attested copies of the Writ of Execution and made the contents there of known to her. The writ of execution and notice to defendant was mailed on November 13, 2013 to Shawn P. Kleeman at 28 Pine Hill Avenue, Mechaniscburg, PA 17050. 06/13/2014 Ronny R. Anderson, Sheriff, who being duly sworn according to law, states this writ of execution is returned as ABANDONED. No action on writ in over 6 months. SHERIFF COST: $89.26 SO ANSWERS, June 13, 2014 (c) CountySuite Sheriff, Teleosoft, Inc. RONZ ANDERSON, SHERIFF _2 el .a. sa , 4/- 3o 7JY3