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Home My WebLink About10-7879Our File No.: 297234 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. PETER GEKAS 202 CONODOGUINET AVE CAMP HILL, PA 17011-4114 Defendant. _F1LED-OFFICE Cdr' i HE- lad' I H 0 N 0 ; 2010 DEC 20 AM D. P3 CUMBERLAND COU%"T'," COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 16 - -?? 7 9 ? fV1, 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 34 S. BEDFORD ST. CARLISLE PA 17013 717-249-3166 P qd •d6 A?q ? r Pt,# /93q,3 deft ,25 9 I?W Our File No.: 29723.4 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. PETER GEKAS 202 CONODOGUINET AVE CAMP HILL, PA 17011-4114 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 PETER GEKAS, an adult individual residing at 202 CONODOGUINET AVE CAMP HILL, PA 17011-4114. 3. Plaintiff, ADVANTAGE ASSETS II, INC., is the Assignee and Successor in Interest of Account # ending in 7543; and said account was issued to Defendant(s) by CITIBANK/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 $2,643.71. 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 $2,643.71 and requests this Court award costs to the extent permitted by applicable law. APOTH=R SSOCIATES, P.C. Atto y r Plainti A Law Firm En a d in t Collection BY: David J. Apothaker, Esquire Dated: 12/20/2010 Our File No.: 297234 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 r ati g to unworn falsification to authorities. David J. Wthaker, Esquire Attorn v for Plaintiff DATE: 12/20/2010 ADVANTAGE ASSETS II, INC. PETER GEKAS 202 CONODOGUINET AVE CAMP HILL, PA 17011-4114 STATEMENT OF ACCOUNT Debtor's Name: PETER GEKAS Account Number: ending in 7543 Original Creditor: CITIBANK/THE HOME DEPOT Balance Due: $2,643.71 Our File No.: 297234 EXHIBIT "A" 297234 Request for Service R. Thomas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.6390 Fx: 717-240-6397 Plaintiff/s: Court Number: ADVANTAGE ASSETS Il, INC. Expiration Date: Type of Action: Civil Action Defendants: PETER GEKAS Serve Upon: PETER GEKAS Address for Service: 202 CONODOGUINET AVE CAMP HILL, PA 17011-4114 Alternate Address for Service: Type of Service: () Personal (X) Adult in Charge () Deputize () Certified Mail (} Posting Special Service Instructions: ** If service is to be made by deputized service to another county please specify which county Filing Attorney Information: Name: Apothaker & Associates, P.C. Address: 520 Fellowship Road C306 Mount Laurel, NJ 08054 Telephone: 215-634-8920 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor PE HIN S 9 L Vfti fi A Advantage Assets Il, Inc. vs. Peter Gekas Case Number 2010-7879 SHERIFF'S RETURN OF SERVICE 12/28/2010 06:10 PM - Robert Bitner, Deputy Sheriff, who being duly sworn according to law, states that on December 28, 2010 at 1810 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Peter Gekas, by making known unto himself personally, at 202 Conodoguinet Avenue, Camp Hill, Cumberland County, Pennsylvania 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $41.50 January 04, 2011 SHERIFF'S OFFICE OF CUMBERLAND COUNTY 4 "' 11 JAiNN -7 PM 12: t _???h 1l't R-O RT BITNER, DE UTY SO ANSWERS, RON ry R ANDERSON, SHERIFF