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HomeMy WebLinkAbout08-3716 Our File No.: 167589 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esq. Attorney I.D.438423 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 (215) 634-8920 Attorneys for Plaintiff CAVALRY PORTFOLIO SERVICES, LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, VS. ALICE L FORBES 9 BRIAR LN CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY d; NO.: 08 - 3'711 .V L '-lJ"' 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 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 I% 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 CAVALRY PORTFOLIO SERVICES, LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, vs. ALICE L FORBES 9 BRIAR LN CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: ©Y- 37/4 C:,d- r-e. CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is CAVALRY PORTFOLIO SERVICES, LLC c/o Apothaker & Associates, P.C., 2417 Welsh Road, Suite 21 #520, Philadelphia, PA 19114. 2. Defendant(s) is/are ALICE L FORBES, an adult individual residing at 9 BRIAR LN CAMP HILL, PA 17011. 3. Plaintiff, CAVALRY PORTFOLIO SERVICES, LLC, is the Assignee and Successor in Interest of Account #4356002508257225; and said account was issued to Defendant(s) by BANK OF AMERICA, 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 $3,730.85. 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. 1 r WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $3,730.85 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & Attorney A Law Firm Eng% BY: David J. Dated: 6/17/2008 RTES, P.C. Debt Our File No.: 167589 VERIFICATION David J. Apothaker, Esc. 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 to gnsworn falsification to authorities. David"J-•Apothaker Attorney for Plaintiff DATE: 6/17/2008 ALICE L FORBES 9 BRIAR LN CAMP HILL, PA 17011 STATEMENT OF ACCOUNT CAVALRY PORTFOLIO SERVICES, LLC Debtor's Name: ALICE L FORBES Account Number: 4356002508257225 Original Creditor: BANK OF AMERICA Balance Due: $3,730.85 Our File No.: 167589 EXHIBIT "A" ,-, -Ti SOD W ;' i 4 C613 I SHERIFF'S RETURN - REGULAR CASE NO: 2008-03716 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND CAVALRY PORTFOLIO SERVICES VS FORBES ALICE L GERALD WORTHINGTON Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPT,ATT\TT 1.; V(-)MTna FORBES ALICE L DEFENDANT was served upon the at 1026:00 HOURS, on the 26th day of June 2008 at 9 BRIAR LN CAMP HILL, PA 17011 ALICE FORBES by handing to 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: So Answers: Docketing 18.00 Service 14.00 Affidavit 00'"`r'A r Surcharge 10.00 R. Thomas Kline 171OAlo P .00 42.00 06/27/2008 APOTHAKER & ASSOCIATES Sworn and Subscibed to By. before me this day Deputy S yiff LIT of A.D. Our File No.: 167589 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 CAVALRY PORTFOLIO SERVICES, LLC Plaintiff, vs. ALICE L FORBES Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-3716 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & AS, Attorneys for A Law Firm Engaged j By: kTES, P.C. Collection David J. Apothaker Dated: 7/25/2008 n'D