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Home My WebLink About08-4316. -a Our File No.: 169509 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 ATLANTIC CREDIT & FINANCE INC ASSIGNEE FROM HSBC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, vs. CHRISTIE HOOVER 12 APPALACHIAN TRAIL RD GARDNERS, PA 17324-9052 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY cam. NO.: 08 - OW /& 30 ZL 1 ?JU?? 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 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 ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, vs. CHRISTIE HOOVER 12 APPALACHIAN TRAIL RD GARDNERS, PA 17324-9052 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: D Y y3 /G C4 T, CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC c/o Apothaker & Associates, P.C., 2417 Welsh Road, Suite 21 #520, Philadelphia, PA 19114. 2. Defendant(s) is/are CHRISTIE HOOVER, an adult individual residing at 12 APPALACHIAN TRAIL RD GARDNERS, PA 17324-9052. 3. Plaintiff, ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC, is the Assignee and Successor in Interest of Account #5467020004294347; and said account was issued to Defendant(s) by HSBC, 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 $14,867.05. A hue 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 $14,867.05 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & CIATES, P.C. Attorney or laintiff A Law Firm Ena ed Debt Collection BY: David J. Dated: 7/14/2008 Our File No.: 169509 VERIFICATION C UP.6nu 0. G' nu hereby states that I am 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 unsworn falsification to authorities. (0. AMA A Of?6trttQll?Orif1 Pl ff DATE: I— . % ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC CHRISTIE HOOVER 12 APPALACHIAN TRAIL RD GARDNERS, PA 17324-9052 STATEMENT OF ACCOUNT Debtor's Name: CHRISTIE HOOVER Account Number: 5467020004294347 Original Creditor: HSBC Balance Due: $14,867.05 Our File No.: 169509 EXHIBIT "A" t F J} co ?.c T °>C tt? c oto SHERIFF'S RETURN - REGULAR CASE NO: 2008-04316 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND ATLANTIC CREDIT & FINANCE VS HOOVER CHRISTIE MICHAEL BARRICK Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE HOOVER CHRISTIE was served upon the DEFENDANT , at 0020:49 HOURS, on the 12th day of August , 2008 at 12 APPALACHIAN TRAIL RD GARDNERS, PA 17324-9052 DEFENDANT 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: Docketing 18.00 Service ? 8.00 g Affidavit .00 gl? Surcharge OK? 10.00 r% r% J V . V V Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 08/13/2008 APOTHAKER & ASSOCIATES By. Deputy S er' 4f? of A. D. Our file No.: 169509 ,. Z- APOTHAKER & ASSOCIATES, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff Attorney ID# 307949 ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC Plaintiff, vs. CHRISTIE HOOVER C?? ?!f COURT OF COMMON PLEAS CUMBERLAND COUNTY DOCKET NO.: 08-4316 Civil Action STIPULATION IN LIEU OF JUDGMENT Defendant. The matters and things in controversy having been discussed by and between the parties, and a settlement having been agreed upon: It is on April 28, 2010, STIPULATED by and between Plaintiff, ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC, and Defendant, CHRISTIE HOOVER parties as follows: 1. Defendant agrees to pay the sum of $15,932.83, which sum Plaintiff agrees to accept in full settlement of its claim herein, inclusive of counsel fees and court costs. 2. As of this date, payments totaling $10,000.00 have been applied to the amount of $15,932.83, and the amount due and owing as of April 28, 2010 is $5,932.83. 3. The sum aforesaid of $5,932.83 shall be paid by the by Defendant, CHRISTIE HOOVER, to the attorneys for Plaintiff in the following manner: a. $500.00 to be paid on or before the 25`h day of each month, beginning May 25, 2010 until paid in full. All checks are to made payable to ATLANTIC INC. ASSIGNEE FROM HSBC, and sent to: Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Our file No.: 169509 4. In the event Defendant fails to pay in accordance with the terms set forth in this Stipulation, then, and in that event, Plaintiff shall be entitled to obtain the entry of Judgment against Defendant ex parte, in the sum of $15,932.83, giving Defendant credit for any sums actually paid pursuant to the terms of this Stipulation. 5. In the event of default as aforesaid, Plaintiff shall be entitled to obtain the entry of Judgment upon ex parte application, with supporting certification, and with notice to Defendant only in the form of a copy of the application addressed to CHRISTIE HOOVER by first-class, postage prepaid. We hereby consent to the form and entry of the within Stipulation. APOTHAKER & ASSOCIATES, P.C. Attorneys for Pli }}tiff A Law Fixit-T-nea-eed invD?bt Collection By: Esquire CHRISTIE HOOVER