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HomeMy WebLinkAbout10-1195w Our-,File No.: 246364 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, E9quire 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. JOSEPH M MALIS 142 15TH ST APT N NEW CUMBERLAND, PA 17070 Defendant. 241 fan !'c it. 10 COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 10 - 1145 NOTICE a; V i l -rGr'M 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 O *q& -OO PA p'i'N Cry 1710 (o I 137a6q qb Our File No.: 2463 64 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Es$uire Attorney I.D. 438423 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. JOSEPH M MALIS 142 15TH ST APT N NEW CUMBERLAND, PA 17070 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: )O ` 119<?lv, 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 JOSEPH M MALIS, an adult individual residing at 142 15TH ST APT N NEW CUMBERLAND, PA 17070. 3. Plaintiff, ADVANTAGE ASSETS II, INC., is the Assignee and Successor in Interest of Account #5148730950023121; 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 $30,146.25. 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 $30,146.25 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & ASS TES, P.C. Attorney foVebt ntiff A Law Firm Ensa?e Collectioi BY: Dated: 2/16/2010 David J. ApothKer, Esquire Our File No.: 246364 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 unk4signed understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 relat' to worn falsification to authorities. David J. Apo aker, Esquire Attorney for Plaintiff DATE: 2/16/2010 ADVANTAGE ASSETS II, INC. JOSEPH M MALIS 142 15TH ST APT N NEW CUMBERLAND, PA 17070 STATEMENT OF ACCOUNT Debtor's Name: JOSEPH M MALIS Account Number: 5148730950023121 Original Creditor: CHASE BANK USA N.A. Balance Due: $30,146.25 Our File No.: 246364 EXHIBIT "A" SHERIFF'S OFFICE OF CUMBERLAND LINTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Edward L Schorpp Solicitor ~piit~"41 at ~tlzgjlpr/~~~~ v_ '~-~ ~~ ~~ ~~~OIAAY 2010 MAR --3 ~ g; ~~ CU PEA.: `-%~~Vt1' Advantage Assets II, Inc. vs. Joseph M. Malis Case Number 2010-1195 SHERIFF'S RETURN OF SERVICE 02/25/2010 06:30 PM -Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on February 25, 2010 at 1830 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Joseph M. Malis, by making known unto himself personally, at 142 15th Street Apt. N, New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $43.30 SO ANSW February 26, 2010 RON Y. ANDERSON, SHERIFF 1' Deput heriff !c Ce~.uurSuite. Srerf'. ieic:r,>oft. Der, �E cu David D. �3uelT 9 e Q Renee Simpson Prothonotary ' ; y 15` Deputy Prothonotary �irkS. Solionage, ESQ Irene E. w Solicitor 7750 2nd Deputy Prothonotary Office of the Prothonotary Cumber(ancfCounty, Pennsylvania /6 119s CIVIL TERM ORDER OF TERMINATION OF COURT CASES AND NOW THIS 29TH DAY OF OCTOBER, 2013,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 One Courthouse Square • Suite 100 • Carlisle, PA 17013 • (717)240-6195 • Ea., (717)240-6573