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Home My WebLink About10-4531 Our File No.: 257646 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. 7322 SOUTHWEST FREEWAY, SUITE 1600 HOUSTON, TX 77074 Plaintiff, vs. FRANK G FLETCHER 311 RAVEN CT MECHANICSBURG, PA 17050 Defendant. Fl?C1? .- :ti Jr C12 f?N?Y COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: ID - y53I 0, ;v%kT'PXw, NOTTC E 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 34 S. BEDFORD ST. CARLISLE PA 17013 717-249-3166 Q ga.00 P A Ar-1 C1 1 R20I R! a yy8y8 e 1 Our File No.: 257646 APOT1 AKER & 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. 7322 SOUTHWEST FREEWAY, SUITE 1600 HOUSTON, TX 77074 Plaintiff, VS. FRANK G FLETCHER 311 RAVEN CT MECHANICSBURG, PA 17050 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is ADVANTAGE ASSETS II, INC., 7322 SOUTHWEST FREEWAY, SUITE 1600, HOUSTON, TX 77074. 2. Defendant(s) is/are FRANK G FLETCHER, an adult individual residing at 311 RAVEN CT MECHANICSBURG, PA 17050. 3. Plaintiff, ADVANTAGE ASSETS II, INC., is the Assignee and Successor in Interest of Account # ending in 3339; and said account was issued to Defendant(s) by CITIBANK (SOUTH DAKOTA) N.A./THE HOME DEPOT, 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 $3,831.19. 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 $3,831.19 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER AS CIATES Attorne for laintiff A Law Firm Ent Zed n De Collecti BY: David J. Apothaker, Esquire Dated: 7/1/2010 Our File No.: 257646 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 worn falsification to authorities. i David J. 4Qwkief,Esquire Attornv for Plaintiff DATE: 7/1/2010 ADVANTAGE ASSETS II, INC. FRANK G FLETCHER 311 RAVEN CT MECHANICSBURG, PA 17050 STATEMENT OF ACCOUNT Debtor's Name: FRANK G FLETCHER Account Number: ending in 3339 Original Creditor: CITIBANK (SOUTH DAKOTA) N.A./THE HOME DEPOT Balance Due: $3,831.19 Our File No.: 257646 EXHIBIT "A" SHERIFF'~5 OFFICE OF CUMBERLAND COUNTY Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart SOIICltor ~a~etitr of ~ t,:IHbrr~~~~ ~' ~: E °;~ t'r~ :s yTt ~. , •~ GSFFi4E G' Tom: SHERIFF ~tL~1 r 2010 ~~1~ { 6 AI'i ~~ ~ Advantage Assets II, Inc. vs. Frank G. Fletcher Case Number 2010-4531 HERIFF'S RETURN OF SERVICE 07/09/2010 04:27 PM -Ryan Burge1 2010 at 1623 hours, he defendant, to wit: Frank Mechanicsburg, Cumbe him personally the said Deputy Sheriff, who being duly sworn according to law, states that on July 9, rued a true copy of the within Complaint and Notice, upon the within named .Fletcher, by making known unto himself personally, at 311 Raven Court, end County, Pennsylvania 17050 its contents and at the same time handing to ie and correct copy of the same. ~~- RYAN BURGE EPUTY SHERIFF COST: $37.00 July 12, 2010 SO ANSWERS, ~~ RON R ANDERSON, SHERIFF (cj CountySuite Sheriff. Teleosoft. Inc.