HomeMy WebLinkAbout08-5899
Our File No.: 183949
APOTHAKER & ASSOCIATES, P.C.
BY: DaSid J. Apothaker, Esquire, Esq.
Attorney I.D.#38423
520 Fellowship Road C306
Mount Laurel, NJ 08054
(800) 672-0215
Attorneys for Plaintiff
PALISADES COLLECTION, LLC
c/o Apothaker & Associates, P.C.
520 Fellowship Road C306
Mount Laurel, NJ 08054
Plaintiff,
VS.
GARY C NEGLEY
9 W MAIN STAPT 1
NEWVILLE, PA 17241
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: 08 - 5899 C ivi( (erm
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
4
Our File No.: 183949
APOTHAKER & ASSOCIATES, P.C.
BY: Dadid J. Apothaker, Esquire, Esq.
Attgrney I.D.#38423
520 Fellowship Road C306
Mount Laurel, NJ 08054
(800) 672-0215
Attorneys for Plaintiff
PALISADES COLLECTION, LLC )
c/o Apothaker & Associates, P.C. )
520 Fellowship Road C306 )
Mount Laurel, NJ 08054 )
Plaintiff, )
VS. )
GARY C NEGLEY )
9 W MAIN STAPT 1 )
NEWVILLE, PA 17241 )
Defendant. )
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO..
CIVIL ACTION COMPLAINT
FIRST COUNT
1. Plaintiff is PALISADES COLLECTION, LLC c/o Apothaker & Associates, P.C., 520
Fellowship Road C306, Mount Laurel, NJ 08054.
2. Defendant(s) is/are GARY C NEGLEY, an adult individual residing at 9 W MAIN STAPT 1
NEWVILLE, PA 17241.
3. Plaintiff, PALISADES COLLECTION, LLC, is the Assignee and Successor in Interest of
Account #5407915012509136; and said account was issued to Defendant(s) by HSBC CREDIT SERVICE INC.,
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 $1,645.60. 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
$1,645.60 and requests this Court award Plaintiff
A Law Firm
and costs to the extent permitted by applicable law.
ISOCIATES, P.C.
Plaintiff ,
in Deh? nllentinr
BY:
David J.
, Esquire
Dated: 9/24/2008
Our File No.: 183949
VERIFICATION
David J. Apothaker Esquire 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.
made subject to the penalties of 18 Pa.C.S.A. 4904
understands that the statements therein are
unworn falsification to authorities.
David J. A er, Esquire
Attorney t'bcZJaintiff
DATE: 9/24/2008
PALISADES COLLECTION, LLC
GARY C NEGLEY
9 W MAIN STAPT 1
NEWVILLE, PA 17241
STATEMENT OF ACCOUNT
Debtor's Name: GARY C NEGLEY
Account Number: 5407915012509136
Original Creditor: HSBC CREDIT SERVICE INC.
Balance Due: $1,645.60
Our File No.: 183949
EXHIBIT "A"
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SHERIFF'S RETURN - REGULAR
CASE NO: 2008-05899 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PALISADES COLLECTION LLC
VS
NEGLEY GARY C
TIMOTHY R BLACK , Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE was served upon
NEGLEY GARY C the
DEFENDANT at 0017:30 HOURS, on the 10th day of October , 2008
at 9 W MAIN ST APT 1
NEWVILLE, PA 17241 by handing to
GARY C NEGLEY DEFENDANT
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
Service
Affidavit
Surcharge
10/14/0P 6..r
18.00
11.00
.00
10.00
_ .00
39.00
So Answers:
R. Thomas Kline
10/13/2008
APOTHAKER & ASSOCIATES
By: ,-r_
eputy Sheriff
Sworn and Subscibed to
before me this day
of A. D.
i
Our File No.: 183949
APOTHAKER & ASSOCIATES, P.C.
BY: David J. Apothaker, Esquire
Attorney I.D.# 38423
520 Fellowship Road C306
Mount Laurel, NJ 08054
(800) 672-0215
Attorney for Plaintiff
PALISADES COLLECTION, LLC
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
Plaintiff,
vs.
GARY C NEGLEY
NO. 08-5899
Defendant.
PRAECIPE TO DISMISS WITHOUT PREJUDICE
TO THE PROTHONOTARY:
Kindly dismiss this action without prejudice.
APOTHAKER
A Law Firm
IOCIATES, P.C.
Plaintiff
n Debt Collectioi
By:
David J. Apothaker, Esquire
Dated: November 20, 2008
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