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HomeMy WebLinkAbout08-4680%Our File No.: 13 8129 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. JOHN VERRECCHIO 107 E CLEARVIEW DR CAMP HILL, PA 17011-4051 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: M - q(080 NOTICE o'-w4 c (L." 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 PORTFOLIO RECOVERY ASSOCIATES, LLC c/o Apothaker & Associates, P.C. 2417 Welsh Road, Suite 21 #520 Philadelphia, PA 19114 Plaintiff, vs. COURT OF COMMON PLEAS CUMBERLAND COUNTY JOHN VERRECCHIO 107 E CLEARVIEW DR CAMP HILL, PA 17011-4051 Defendant. NO.: OP- 'fG 70 C -. 4- "T?... CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is PORTFOLIO RECOVERY ASSOCIATES, LLC c/o Apothaker & Associates, P.C., 2417 Welsh Road, Suite 21 #520, Philadelphia, PA 19114. 2. Defendant(s) is/are JOHN VERRECCHIO, an adult individual residing at 107 E CLEARVIEW DR CAMP HILL, PA 17011-405 1. 3. Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, is the Assignee and Successor in Interest of Account #5458004581002993; 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 $5,466.79. 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 $5,466.79 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. TES, P.C. APOTHAKER & /inlE'? ?fiff Attorney fA Law Firm Engage bt Collection BY: David Dated: 7/25/2008 Our File No.: 138129 VERIFICATION Tiff an Ross hereby states that I am Legal Specialist 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 unworn falsification to authorities. Jc" Plainti DATE: PORTFOLIO RECOVERY ASSOCIATES, LLC JOHN VERRECCHIO 107 E CLEARVIEW DR CAMP HILL, PA 17011-4051 STATEMENT OF ACCOUNT Debtor's Name: JOHN VERRECCHIO Account Number: 5458004581002993 Original Creditor: HSBC Balance Due: $5,466.79 Our File No.: 138129 EXHIBIT "A" G 0 F J CO SHERIFF'S RETURN - REGULAR CASE NO: 2008-04680 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PORTFOLIO RECOVERY ASSOCIATES VS VERRECCHIO JOHN RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon VERRECCHIO JOHN the DEFENDANT , at 2008:00 HOURS, on the 22nd day of August 2008 at 107 E CLEARVIEW DRIVE CAMP HILL, PA 17011 by handing to JOHN VERRECCHIO a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 14.00 Affidavit .00 Surcharge 10.00 9)0410$ QN. .00 42.00 Sworn and Subscibed to before me this day of , So Answers : R. Thomas Kline 08/25/2008 APOTHAKER & ASSOCIATES By: Deputy Sheriff A. D. Our File No.: 13 8129 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 PORTFOLIO RECOVERY ASSOCIATES, LLC Plaintiff, VS. JOHN VERRECCHIO Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-4680 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, JOHN VERRECCHIO, in the default of an Answer, in the amount of $5,703.10 computed as follows: Amount claimed in complaint: $5,466.79 Amount Paid: - $(0.00) Interest from July 25, 2008 to 05/14/09 at the legal interest rate of 6.000 per annum $236.31 Costs $0.00 Attorney fees $0.00 TOTAL $5,703.10 I hereby certify that the appropriate Notices of Default, as attached have been mailed in accordance with Pa.R.Civ.P. 237.1 on the dates indicated on the Notices. I certify Defendant, JOHN VERRECCHIO, last know address is 107 E CLEARVIEW DR CAMP HILL, PA 17011-4051. APOTHAKER Attorn s A Law Firm En ag By: ` David J. SOCIATES, P.C. Plaintiff in Debt Collection Dated: 5/14/2009 16 Our File No.: 13 8129 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff PORTFOLIO RECOVERY ASSOCIATES, LLC Plaintiff, VS. JOHN VERRECCHIO Defendant. Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-4680 . SS. 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 107 E CLEARVIEW DR CAMP HILL, PA 17011-4051. We inquired with the web site of the Deft Boulevard, Suite 400, Arlington, VA 22209-2593, if Mary M. Snavely-Dixon, Director of the indicated that the Defendant(s) is/are not in the i David J. Apot lacer Attorney for Plaintiff Data Center, located at 1600 Wilson s) is/are in any branch of the military. Data Center has sent back our inquiry 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. Deparkneat cfl ase Manpower Data Center MAY 14-2009 08:40:46 Mkwy Stow Report Pursuant to the Servicemnembers t. ai RefiefAct VERRRCCHIC ? JOHN Based on the Wanuadoo ycau bave JanmishedL the DND C does rode pyassess my ktar n that the iacbvidtxat Barra ? on active, daty. Upon searching the inf mmabon data hanks of The Dep nt of Dafam Manpower Data Curter, based on the anformakim that you provided, flee above is the cornrsat 11 1 of the kK&-;&d as to all branches ofthe MIt ry. A x ,c..a,.a?.. Mary M. aw*-D Direct Deperhment ofD e - Manpower Data Center 1600 Wilson Blvd., Sake 4W Arfingtom, VA 22209=2593 The Defense Manpower Data Center (D) is an organkatio© of the Departument of Delense that maintains the Die Eurchneat and W}* Reporting Sy m m (DES) database which as the official source of data on d WW for n9my medical care and other d9WILy system- The Dapartmmt ofDefmse strou* supports the amEwcemient oftbe Services bars Cif RA£Act [30 t1SCS AppL §§:501 eat seq] (SCRA) (fimmerly the SMere and Sailors" Civil Rdkf'Act of 1940)_ DMDC has issued hundreds offhousmatis of -does not possess any ids indicabg that the nclividual is cutreertly an active Y''" responses, and has c came ed a estat rare. In the event the aad'naidual re&reaced above, or any family ; $kaid„ ar teprucubfm asn is in am mm= Shit fhe ind viduml is can active duty, orr in a eatitlydd to the pry ofrhe SCRA, you ire strong encooraSed to obtainforther vailicadon of the pav an"s active &ty states by coatacaiag that persods Miry Service via the'd dirk nit"' URL provided below. X you have evidence the person is on acti e-d ly and you fal to obtain this add'aion d Mikery Service via, prmisions of the SCRA may be invoiced xt yoga. Kyou obtain 1i rdur in'orn ndm about The person (e-&. an SSN, kopmoired accuracy of DOB, a miti3e name}, you can sabrmit your mqmgmt again at this Web sire and we will provide a new cerdlica a for drat query, Ibis response re i current active der only For historical. mfoxnabon. please contact the Military Service SCRA points- of-contact See` bwjhyww Moat WARNIN'Q This cectilirme was provided based on a name and Social Security nzaber (SSM provided by the requester - Providiing an erroneous smme or SSN will carte an emoneous catFK*e to be provided. R Z9'CRrJAZ CQY 138129 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY PORTFOLIO RECOVERY ASSOCIATES, LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) JOHN VERRECCHIO ) NO. 08-4680 To: JOHN VERRECCHIO 107 E CLEARVIEW DR CAMP HILL, PA 17011-4051 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: September 22, 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 DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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 DA J. APOTHAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC A Law Firm Engaged in Debt Collection 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff Attorney ID #38423 SHERIFF'S RETURN - REGULAR CASE NO: 2008-04680 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND Lre, PORTFOLIO RECOVERY ASSOCIATES FSEP w 4 2008 VERRECCHIO JOHN RONALD HOOVER , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon VERRECCHIO JOHN the DEFENDANT , at 2008:00 HOURS, on the 22nd day of August , 2008 at 107 E CLEAR.VIEW DRIVE CAMP HILL, PA 17011 by handing to JOHN VERRECCHIO a true and attested copy of COMPLAINT & NOTICE together with and at the same time directing His attention to the contents thereof. Sheriff's Costs: Docketing 18.00 Service 14.00 Affidavit .00 Surcharge 10.00 .00 42.00 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 08/25/2008 APOTHAKER & ASSOCIATES By: 62*i?z Deputy Sheriff of A. D. 33 r _ OF THE 'T 4RY 2C 9Ilj Y 20 14111 103 : 0 Cui 4 W oo Po A rrf alc,'tr I sq%og Uea. kadA4 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: JOHN VERRECCHIO 107 E CLEARVIEW DR CAMP HILL, PA 17011-4051 PORTFOLIO RECOVERY ASSOCIATES, LLC Plaintiff, vs. JOHN VERRECCHIO Defendant. NOTICE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-4680 Civil Action 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, Esc. at this telephone number: 215-634-8920 5/a% y