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Home My WebLink About14-7326 Supreme Court of Pennsylvania Co111 'of C o><i�>«ion Fleas For C U�,�T<' S11E'ef or Prothonotan, Use Only C'UMBERLA=ND coull-t ; Docket No: The il?/b •Motion collected on this for in is used solely dor cow-t adniinisn ration purposes. This fibrin does not supplement or replace the filing and service of pleadings or other papers as required by law or rules of court. S Commencement of Action: E M Complaint ❑ Writ of Summons ❑ Petition E] Transfer from Another Jurisdiction E]Declaration of Taking C Lead Plaintiff's Name: Lead Defendant's Name: T AMERICR.EDIT FINANCIAL SERVICES,INC.D/B/A TREVOR G BYERS I GM FINANCIAL O Are money damages requested? M Yes ❑ No Dollar Amount Requested: M within arbitration limits N (check one) ❑ outside arbitration limits Is this a Class Action Suit? ❑ Yes M No Is this an MDJAppeal? ❑ Yes M No A Name of Plaintiff/Appellant's Attorney: Apothaker Scian P.C. ❑ Check here.if you have no attorney (are a Self-Represented [Pro Se] Litigant) Nature of the Case: Place an"X"to the left of the ONE case category that most accurately describes your PRIMARY CASE.If you are making more than one type of claim, check the one that you consider most important. TORT(do not include Mass Tort) CONTRACT(do not include Judgments) CIVIL APPEALS ❑Intentional ❑ Buyer Plaintiff Administrative Agencies ❑ Malicious Prosecution ❑ Debt Collection: Credit Card ❑ Board of Assessment ❑ Motor Vehicle M Debt Collection: Other ❑ Board of Elections ❑Nuisance ❑ Dept. of Transportation ❑ Premises Liability ❑ Statutory Appeal: Other ❑ Product Liability(does not S include mass tort) El Employment Dispute: Discrimination E ElSlander/Libel/Defamation El Other: El Employment Dispute: Other C ElZoning Board T ❑ Other: I ❑ Other: O MASS TORT NEI Asbestos ❑ Tobacco ❑ Toxic Tort-DES REAL PROPERTY MISCELLANEOUS ❑ Toxic Tort-Implant ❑ Ejectment ❑ Common Law/Statutory Arbitration ❑ Toxic Waste ❑ Eminent Domain/Condemnation ❑ Declaratory Judgment B ❑ Other: ❑ Ground Rent ❑ Mandamus ❑ Landlord/Tenant Dispute ❑ Non-Domestic Relations ❑Mortgage Foreclosure: Residential Restraining Order ❑Mortgage Foreclosure: Commercial ❑ Quo Warranto PROFESSIONAL ❑Partition ❑ Replevin LIABLITY ❑ Quiet Title ❑ Other: ❑ Dental ❑ Other: ❑ Legal ❑ Medical ❑ Other Professional: r Our File No.: 378389 Apothaker Scian P.C. r 1 ' 01 By: David J. Apothaker, Esquire (` `f :ref; f;`';�? ''T', Attorney I.D. #38423 t'� ``'F '�Y'( " ' } 520 Fellowship Road Suite C306 PO Box 5496 Mt. Laurel,NJ 08054-5496 (800)672-0215 Attorneys for Plaintiff AMERICREDIT FINANCIAL SERVICES, INC. ) COURT OF COMMON PLEAS D/B/A GM FINANCIAL ) CUMBERLAND C UNT 801 CHERRY ST ) . FORT WORTH, TX 76102 ) NO.: H- )3d6 Plaintiff, ) vs. ) TREVOR G BYERS ) 120 FROST RD ) GARDNERS, PA 17324 ) 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 34 S. BEDFORD ST. CARLISLE PA 17013 717-249-3166 awJ I� 09 T Our File No.: 378389 Apothaker Scian P.C. By: David J. Apothaker, Esquire Attorney I.D. #38423 520 Fellowship Road Suite C306,PO Box 5496 Mt. Laurel,NJ 08054-5496 (800)672-0215 Attorneys for Plaintiff AMERICREDIT FINANCIAL SERVICES, ) COURT OF COMMON PLEAS INC. D/B/A GM FINANCIAL ) CUMBERLAND COUNTY 801 CHERRY ST ) FORT WORTH, TX 76102 ) NO.: Plaintiff, ) vs. ) TREVOR G BYERS ) 120 FROST RD ) GARDNERS, PA 17324 ) Defendant. ) CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is AMERICREDIT FINANCIAL SERVICES, INC. D/B/A GM FINANCIAL, 801 CHERRY ST, FORT WORTH, TX 761.02. 2. Defendant(s) is/are TREVOR G BYERS, an adult individual residing at 120 FROST RD, GARDNERS, PA 17324. 3. The Defendant, TREVOR G BYERS, entered into a Finance Agreement ("Agreement")with the Plaintiff for the purposes of purchasing a vehicle. 4. Defendant breached the terms of said Agreement by failing to make payments when due. 5. There is a deficiency due and owing to the Plaintiff in the amount of$9,191.10. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant for the sum of$9,191.10 and requests this Court award costs to the extent permitted by applicable law. Apotbian AttoA Law Firm Election BY: David J. Ap haker, Esquire Our File No.: 378389 378389 VERIFICATION 1, �Uk" -hereb state that I am Y for Plaintiff.I hereby verify that, upon information and belief,the statements made in the foregoing Civil Action Complaint are true and accurate. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S. §4904 relating to unsworn falsification to authorities. V y AMit e Defendant's Name: TREVOR G BYERS Account Number: ending in 5473 4 Ronny R Anderson Sheriff Jody S Smith Chief Deputy Richard W Stewart Solicitor SHERIFF'S OFFICE OF CUMBERLAND COUNTY t_t L' Lt C)FF;CEOF THE. I 73111 C 30 AM 10: 14 CUMBERLAND COUNTY PENNSYLVANIA Americredit Financial Services, Inc. d/b/a GM Financial vs. Trevor G Byers Case Number 2014-7326 SHERIFF'S RETURN OF SERVICE 12/23/2014 08:17 PM - Deputy Jason Kinsler, being duly sworn according to law, served the requested Complaint & Notice by handing a true copy to a person representing themselves to be Sally Stambaugh, girlfriend, who accepted as "Adult Person in Charge" for Trevor G Byers at 120 Frost Road, South Middleton Township, Gardners, PA 17324. SON KINSLER, DEPUTY SHERIFF COST: $40.43 SO ANSWERS, December 29, 2014 RONNY R ANDERSON, SHERIFF (c) CountySuite Sherif:, Teieosoff, Inc.