The URL can be used to link to this page

Home My WebLink About08-6060a Our File No.: 167141 'APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff PORTFOLIO RECOVERY ASSOCIATES, LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. TERESA A HEINBAUGH 97B PARTRIDGE CIR CARLISLE, PA 17013-8749 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: a$ - (ooW Cw; < tef%l 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 Our File No.: 167141 'APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff PORTFOLIO RECOVERY ASSOCIATES, LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. TERESA A HEINBAUGH 97B PARTRIDGE CIR CARLISLE, PA 17013-8749 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0 0- 4 6 40 0,?;( -7 «-,- CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is PORTFOLIO RECOVERY ASSOCIATES, LLC c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are TERESA A HEINBAUGH, an adult individual residing at 97B PARTRIDGE CIR CARLISLE, PA 17013-8749. 3. Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, is the Assignee and Successor in Interest of Account #5409790800409239; and said account was issued to Defendant(s) by PROVIDIAN, 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 $623.19. 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 $623.19 and requests this Court award Plaintiff attorney's feT d costs to the extent permitted by applicable law. APOTHAKER & SIATES, P.C. orne for tiff A Law Firm En ed bt Collection BY: David J. Apgthaker, Esquire Dated: 9/29/2008 Our File No.: 167141 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 unsworn falsification to authorities. David J. Apothaker, Esquire Attorney for Plaintiff DATE: 9/29/2008 PORTFOLIO RECOVERY ASSOCIATES, LLC TERESA A HEINBAUGH 97B PARTRIDGE CIR CARLISLE, PA 17013-8749 STATEMENT OF ACCOUNT Debtor's Name: TERESA A HEINBAUGH Account Number: 5409790800409239 Original Creditor: PROVIDIAN Balance Due: $623.19 Our File No.: 167141 EXHIBIT "A" ' ?n a z-Ti y Q b _ C UP ? -r? SHERIFF'S RETURN - REGULAR CASE NO: 2008-06060 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PORTFOLIO RECOVERY ASSOCIATES VS HEINBAUGH TERESA A 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 HEINBAUGH TERESA A the DEFENDANT , at 0011:44 HOURS, on the 11th day of October , 2008 at 97B PARTRIDGE CIR CARLISLE, PA 17013-8749 MIKE STENEHJEM by handing to ADULT IN CHARGE 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 5.00 Affidavit .00 Surcharge 10.00 n .00 lo/?4/bP `/?` ? 33.00 Sworn and Subscibed to before me this of day So Answers: R. Thomas Kline 10/13/2008 APOTHAKER & ASSOCIATES By: A. D. Our File No.: 167141 APOTHAKER & ASSOCIATES, P.C. -BY: Kimberly F. Scian, Esquire Attorney I.D.# 55140 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff PORTFOLIO RECOVERY ASSOCIATES, LLC COURT OF COMMON PLEAS CUMBERLAND COUNTY Plaintiff, VS. NO. 08-6060 TERESA A HEINBAUGH Defendant. PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys for Plaintiff A Law Firm Engaged in Debt Collection F. Scian, Esquire Dated: February 13, 2009 e"" r,,a ,--? _ aJ ? ' '°i'x _? ? ra w_V. Fti;? - r (--_ ? ?_? ' t ??? _i