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Home My WebLink About07-7483 Our File No.: 117641 , APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esq. Attorney I.D.#38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff PORTFOLIO RECOVERY ASSOCIATES, LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, vs. NANCY J VREELAND 664 SHANNON RD BOILING SPRINGS, PA 17007-9643 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 67- rign Ctvi ( Term 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. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral and Information Service 800-990-9108 AVISO Le han demandado a usted en la corte. Si usted quiere defenderse do estas demandas expuestas en las paginas siguientes, usted tiene veinte (20) dias de plazo al partir de la fecha de la demanda y la notificacion. Hace falta asentar una comparencia escrita o con un abogado v entregar a la corte en forma escrita sus objeciones a las demandas en contra de su persona. Sea avisado que si usted no se defiende, la corte tomara medidas y puede continuar la demanda en contra suya sin previo aviso o notificacion. Ademas, la corte puede decidir a favor del edemandante y requiere que usted compla con todas las provisiones de esta demanda. Usted puede perder dinero o sus propiedades u otros derechos importantes pare usted. LLEVE ESTA DEMANDA A UN ABOGADO INMEDIATAMENTE. SI NO TIENE ABOGADO O SI NO TIENE EL DINERO SUFICIENTE DE PAGAR TAL SERVICIO. VAYA EN PERSONA O LLAME POR TELEFONO A LA OFICINA CUYA DIRECCION SE ENCUENTRA ESCRITA ABAJO PARA AVERIGUAR DONDE SE PUEDE CONSEGUIR ASISTENCIA LEGAL. CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral and Information Service 800-990-9108 APOTHAKER 4 ASSOCIATES, P.C. BY: David J. Apothaker, Esq. Attorney. I.D.#38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff PORTFOLIO RECOVERY ASSOCIATES, LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, vs. NANCY J VREELAND 664 SHANNON RD BOILING SPRINGS, PA 17007-9643 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, is a company with its principal place of business located at c/o Apothaker & Associates, P.C., 2417 Welsh Road, Suite 21 #520, Philadelphia, PA 19114. 2. Defendant is NANCY J VREELAND, an adult individual residing at 664 SHANNON RD BOILING SPRINGS, PA 17007-9643. 3. At the special instance and request of Defendant, Plaintiff sold and delivered to Defendant goods and/or services at the times, of the kinds, in the quantities, and for the prices set forth in Plaintiffs records. A true and correct copy of which is attached hereto, incorporated herein by reference and designated Exhibit "A". 4. Defendant received and accepted the goods and/or services described in Exhibit "A". 5. The prices set forth in Exhibit "A" are the fair, reasonable and market prices for said goods and/or services, and the prices which Defendant agreed to pay. 6. All credits, if any, to which Defendant is entitled, are set forth in Exhibit "A". 7. In addition, Plaintiff avers that Defendant has failed and continues to fail to make any payments, leaving a balance due and owing of $5,520.01. 1 8. Although, demand has been made, Defendant has failed to make payment of the amount due as above. . 9. The original creditor is WASHINGTON MUTUAL BANK. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $5,520.01 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & ASSOCIATES, P.C. Attorne o Plaintiff A Law Firm E aged ' Debt Collection BY: Dated: 11/27/2007 Our File No.: 117641 A VERIFICATION David J Anothaker Esa 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 "Sworn falsification to authorities. DavidApothaker Attorney or Plaintiff DATE: 11/27/2007 4 } ??j / . PAYMENT MINIMUM BALANCE AS OF ACCOUNT l DUE DATE PAYMENT 01MI 2006 NUMBER P.O Box 660433. Dales, TX 75266-0433 o2io2ros 5939.00 54,363.96 4479-481400841009 lndicd" C11r10e of Addrps Below (use blue or bl ck fok) AMOUNT ENCLOSED (use blue or black ink) Address Coy - State A t. $ OF-IFIFIF-1. ?? Home Phone yy ph N Make Checks Payable to Providian 000 E -Mail WASHINGTON MUTUAL CARD SERVICES NANCY J VREELAND > E j P.O. BOX 660487 1149 RINGWOOD AVE ?3J51UG DALLAS TX 75266-0487 HASKELL NJ 07420-1516 `` (?III?III ?IIIII'1'?IIIIIII('IIIIIII'?11 ?1'111I I1I'I?IItII?111I lilt 11111111 lilt 11till INIA 1111'111111" 4479481400841009 0093900 0438398 0011700 06 DETACH HERE C COLR9001 6092 0194 546 7 060106 Pape 1 of 1 N 000 13665 .... -• .=.aaaanycs - YOUR ACCOUNT IS PAST DUE AND OVER ITS CREDIT LIMIT. Please pay the minimum payment listed above along with the overlimit amount immediately or call us at 1-800-280-9441 Your account is closed. Any balance you have will continue to accrue finance charges and fees and you will continue to receive billing statements until your balance is paid in full. Please destroy any checks and credit cards relating to this account. You will also need to cancel all automatic charges that are billed to this account. Closing your account does not stop S these charges from being submitted by the merchant. Account Summary -- 'iaitboe proviats $4r239U9 Credits & Payments $000 Pu?vilases OtIU@T Gharges .f $34:00 Cash Advances + $000 FI1tA14E CHARQE + ?r1 QS:84 NEW BALANCE - $4,383-98 Transactions Tran Post Date Date Descri lion Jan 04 Jan 04 LATE PAYMENT CHARGE Reference Number Amount FOR BILLING ERRORS AND IMPORTANT INFORMATION, SEE REVERSE SIDE. 0000 =39.00 Balance Category Average Daily Periodic Annual % Dai Balance Rate Rate APR' Standard Purchase - Current Cycle $4,293.91 08P2/O= Standard Cash - Current Cycle 29.99% $0.00 .0822%' 29.99%• ANNUAL PERCENTAGE RATE this billing cycle: 29.99% For 24-hour Automated Account Information, please call 1-800-280-0561 or visit us at www.pn Your account is issued by Washington Mutual Bank, Henderson, NV. Finance Grace Charges Terns $105.89 Term B $0.00 Term B 'These rates may vary )vidian.com 33076 NMN(X)02 CJ ? 3-° 00 - ? 7 co SHERIFF'S RETURN - REGULAR CASE NO: 2007-07483 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PORTFOLIO RECOVERY ASSOCIATES VS VREELAND NANCY J KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon VREELAND NANCY J the DEFENDANT , at 1636:00 HOURS, on the 26th day of December-, 2007 at 664 SHANNON RD BOILING SPRINGS, PA 17007-9643 by handing to NANCY VREELAND a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.64 Affidavit .00 Surcharge 10.00 Jlo310 8 9, .00 36.64 Sworn and Subscibed to before me this day of , So Answers: .y R. Thomas Kline 12/28/2007 APOTHAKER & ASSOCIATES By: 1?? /,-?/ Dep ty S eri f A.D. V Our File No.: 117641 APOTHAKER & ASSOCIATES, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff David J. Apothaker, Esquire Attorney ID #38423 PORTFOLIO RECOVERY ) ASSOCIATES, LLC ) Plaintiff, ) vs. ) NANCY J VREELAND } Defendant. } COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 07-7483 Civil Action PRAECIPE TO ENTER DEFAULT JUDGMENT TO THE PROTHONOTARY: Please enter a default judgment in favor of plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC and against Defendant, NANCY J VREELAND, for failure to answer or otherwise respond to the Complaint - Civil Action. The Complaint was served upon the defendants on December 26, 2007 by the CUMBERLAND Sheriff's Department. Copies of the proofs of service are attached hereto as Exhibit "A". I certify, a copy of the Notice of Intention To Take Default was mailed on January 29, 2008, and also attached hereto. Assess damages in the amount of: (a) Balance: $5,520.01 (b) Interest from November 27, 2007 $245.00 TOTAL $5,765.01 APOTHAKER A Law Firm By: Plaintiff in Debt Collection Dated: 10/7/2008 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff PORTFOLIO RECOVERY ASSOCIATES, LLC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, vs, NANCY J VREELAND NO.: 07-7483 Civil Action Defendant. 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 664 SHANNON RD BOILING SPRINGS, PA 17007-9643. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 20 -2593, if the Defendant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the efe a Manpower Data Center has sent (s,,) 's/are not i e military. back our inquiry indicated that the Defendant Dave J. Apothaker Attorney for Plaintiff The above signed understands that the statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Request for Military Status Department of Defense Manpower Data Center Military Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 2 AUG-23-2008 14:41:22 < Last Name First/Middle Begin Date Active Duty Status Service/Agency VREELAND NANCY J Based on the information you have furnished, the DMDC does not possess any information indicating that the individual is currently on active duty. Upon searching the information data banks of the Department of Defense Manpower Data Center, based on the information that you provided, the above is the current status of the individual as to all branches of the Military. nay Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defense that maintains the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the official source of data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil Relief Act [50 USCS Appx. §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1940). DMDC has issued hundreds of thousands of "does not possess any information indicating that the individual is currently on active duty" responses, and has experienced a small error rate. In the event the individual referenced above, or any family member, friend, or representative asserts in any manner that the individual is on active duty, or is otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain further verification of the person's active duty status by contacting that person's Military Service via the "defenselink.mil" URL provided below. If you have evidence the person is on active-duty and you fail to obtain this additional Military Service verification, provisions of the SCRA may be invoked against you. If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for that query. This response reflects current active duty status only. For historical information, please contact the Military Service SCRA points-of-contact. See: http://www.defenselink-mil/faq/pis/PC09SLDR.htm1 WARNING: This certificate was provided based on a name and Social Security number (SSN) provided https://www.dmdc.osd.mil/scra/owa/scra.prc_Select 8/23/2008 Our File No.: 117641 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.#38423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff PORTFOLIO RECOVERY ASSOCIATES, LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, VS. NO. 07-7483 NANCY J VREELAND 664 SHANNON RD BOILING SPRINGS, PA 17007-9643 Defendant. NOTICE OF INTENTION TO TAKE DEFAULT TO: NANCY J VREELAND DATE OF NOTICE: January 29, 2008 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 (10) days from the date of this notice as set forth above, a judgment may be entered against you without a hearing and you may lose your property or other important rights. You should take this notice to a lawyer at once. If you do not have a lawyer or cannot afford one, go to or telephone the following office to find out where you can get legal help: CUMBERLAND COUNTY BAR ASSOCIATION Lawyer Referral and Information Service 800-990-9108 /s/ David J. Apothaker DAVID J. APOTHAKER, ESQUIRE A Law Firm Engaged in Debt Collection 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorney for Plaintiff Attorney ID #38423 SHERIFF', RETURN - REGULAR 1 CASE NO: 2007-07483 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PORTFOLIO RECOVERY ASSOCIATES VS VREELAND NANCY J KENNETH GOSSERT , Sheriff or Deputy Sheriff of Cumberland'County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon VREELAND 14MCY J the DEFENDANT , at 1636:00 HOURS, on the '26th day of December , 2007 at 664 SHANNON RD BOILING SPRINGS, PA 17007-9643 by handing to NANCY VREELAND a true and attested copy of COMPLAINT ? NOTICE together with and at the same time directing Her attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 8.64 Affidavit ,00 Surcharge 10.00 .00 36.64 Sworn and. 5ubscibed to before 'me this day So Answers; R. Thomas Kixne 12/28/2007 APOTHAKER & ASSOCIATES By: of A. 7IDe. ty S ei' f ? i t _ f- . J OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: NANCY J VREELAND 664 SHANNON RD BOILING SPRINGS, PA 17007-9643 PORTFOLIO RECOVERY } ASSOCIATES, LLC ) } Plaintiff, ) VS. ) } NANCY J VREELAND } Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 07-7483 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, Esq. at this telephone number: 215-634-8920 /%9/08