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Home My WebLink About08-6074Our File No.: 184344 A`POTHAKER & 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 PINNACLE CREDIT SERVICES LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. KATHY D LARIMER 109 MAPLE AVE CAMP HILL, PA 17011-4121 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: p$ - l&0,74 Civil JerM 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.: 184344 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 PINNACLE CREDIT SERVICES LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. KATHY D LARIMER 109 MAPLE AVE CAMP HILL, PA 17011-4121 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0f- 60 '74 ec'?-f CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is PINNACLE CREDIT SERVICES LLC c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are KATHY D LARIMER, an adult individual residing at 109 MAPLE AVE CAMP HILL, PA 17011-4121. 3. Plaintiff, PINNACLE CREDIT SERVICES LLC, is the Assignee and Successor in Interest of Account #4147360013322577; 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 $8,063.52. 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 $8,063.52 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & SS IATES, P.C. A Law Firm Engieed iii Debt BY: David I Al)ot r, Esquire Dated: 10/1/2008 Our File No.: 184344 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 to unworn falsification to authorities. David Apothaker, Esquire Attomi?v for Plaintiff DATE: 10/1/2008 PINNACLE CREDIT SERVICES LLC KATHY D LARIMER 109 MAPLE AVE CAMP HILL, PA 17011-4121 STATEMENT OF ACCOUNT Debtor's Name: KATHY D LARIMER Account Number: 4147360013322577 Original Creditor: BANK OF AMERICA Balance Due: $8,063.52 Our File No.: 184344 EXHIBIT "A" (7 ?.a x-a CJ T g' = Go O ,. ti.. rr ? J O D ? r 7 ' ri ::` : y-? SHERIFF'S RETURN - REGULAR CASE NO: 2008-06074 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PINNACLE CREDIT SERVICES LLC VS LARIMER KATHY D 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 LARIMER KATHY D the DEFENDANT , at 1924:00 HOURS, on the 20th day of October , 2008 at 109 MAPLE AVE CAMP HILL, PA 17011-4121 VT R+LTV T\ T TD TKXVM 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 Service 18.00 15.00 Affidavit .00 7 , Surcharge 10.00 R. Thomas Kline fb/fin/0 P .00 43.00 10/21/2008 APOTHAKER & ASSOCIATES Sworn and Subscibed to By: before me this day Deputy Slieriff of A. D. Our File No.: 184344 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 PINNACLE CREDIT SERVICES LLC Plaintiff, VS. KATHY D LARIMER Defendant. TO THE PROTHONOTARY: Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-6074 Civil Action PRAECIPE FOR DEFAULT JUDGMENT Kindly enter judgment against Defendant, KATHY D LARIMER, in the default of an Answer, in the amount of $8,329.73 computed as follows: Amount claimed in complaint: $8,063.52 Amount Paid: - $(0.00) Interest from October 01, 2008 to 05/14/09 at the legal interest rate of 6.000 per annum $266.21 Costs $0.00 Attorney fees $0.00 TOTAL $8,329.73 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, KATHY D LARIMER, last know address is 109 MAPLE AVE CAMP HILL, PA 17011- 4121. APOTHAKER & Attorney, A Law Firm Eng By: :IATES, P.C. Debt Collection David A Dated: 5/14/2009 w oTt"Ry OF THE 2009 MAY 19 P11 ? " 05 t OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: KATHY D LARIMER 109 MAPLE AVE CAMP HILL, PA 17011-4121 PINNACLE CREDIT SERVICES LLC Plaintiff, vs. KATHY D LARIMER Defendant. NOTICE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-6074 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, Esq. at this telephone number: 215-634-8920 nt'., /9, dov? f Our File No.: 184344 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 PINNACLE CREDIT SERVICES LLC Plaintiff, vs. KATHY D LARIMER Defendant. Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-6074 : 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 109 MAPLE AVE CAMP HILL, PA 17011-4121. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-2593, if the Defendant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the Defense indicated that the Defendant(s) is/are not in the military., David J The above signed understands that the statements Section 4904 relating to unsworn falsification to au Data Center has sent back our inquiry are made subject to the penalties of 18 Pa. C.S. Deparkned of Udease Manpower Data Cmow eery Spa Report Pnraaeat as the Servicmxmbers Civil RtWAct 4, 'tit $414'. Mary M. Sasv*-Dvwn. Diiectcc Depeitneent of Ire - Manpower Data Center 1600 n 1, suite 400 Ar ington, VA 22209-2593 AMY-14-200910:06:51 . The Defeene bb npowe r Data Center (DMQ is an eqpearefim of dw Deparrtaaeant Qf Defease that senintim the Defer Er t and Eji ty Rgmdmg Sy*= (DEERS) Jotebw wrier a the vScW sow ce ofdda on qty for =Wary me&3i rare and athrer eligW systenis_ The Depart of Ddeaw stay soppoits the eisfim t of *e Set W-Ac sbexs 044 Relief Act {30 USCS Anx. §§ 501 et segj (SCRA) Oxi nerly the Seders' and Sailo& Civil Rchif Act of 1940). DUDC has issued hundreds of o f'does not possess any information indicating tbatthe ink is cerrendy an active duty" responses, and has eqwiewed a small e rs" rate. In the event the individual referenced above, cc my fenny meunber, Mead. or reprti a defive asserts in any mumeJr drat the individual is on active duty, or is otherwise edited to tie protectim of the SCRA, you are strao* ancoarged to obtain farther won ofthe person's active duty stator by cam parson's May Service vin thou " nC URL provided below- if y ou have evidence the person is on attire-duty and you fail to obtain this additional 1ary Service ve ffka don, provisions of the SCRA may be inwoked ageing you. M you obtain fntther information about the person ( e.g., an SSN, kupraved accuracy of DOB, a middle name), you can sd unit your re goest again at this Web site and we wir provide anew cerfficate for that query. Teas response rcdCds rorrerrt actewe duty st only. For listarica! ofarenabM please contact tie May Service SCRA pomb- af-contact. See: l# fAvww.defenscW WARNNCr. Ibis cease was p uyided based on a carne and Sow S (SSN) prvv deed by the requester. Providing an croineow aamc or SSN will cause an esronem ate to be pry Rspa"M_ "FVWMFZFX Upon searching the i nibranation data banks of dke 1 art lent of Defrnse Manpower Dda Ceuta. based an the isfannadan drat you provided. the above is the current std oft he individual, as to all branches of die Wtwy. 184344 OFFICE OF THE PROTHONOTARY ' COURT OF COMMON PLEAS CUMBERLAND COUNTY PINNACLE CREDIT SERVICES LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) KATHY D LARIMER ) NO. 08-6074 To: KATHY D LARIMER 109 MAPLE AVE CAMP HILL, PA 17011-4121 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: December 03, 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 ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 BAR . \h\ DA I 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: 2008-06074 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PINNACLE CREDIT SERVICES LLC l 0, b t ? VS lid U - ; j NO'S 5 ..'3 LARIMER KATHY D 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 LARIMER KATHY D the DEFENDANT at 1924:00 HOURS, on the 20th day of October 2008 at 109 MAPLE AVE CAMP HILL, PA 17011-4121 by handing to KATHY D LARIMER 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 15.00 Affidavit .00 Surcharge 10.00 .00 43.00 Sworn and Subscibed to before me this day of r So Answers: R. Thomas Kline 10/21/2008 APOTHAKER & ASSOCIATES By: ??-IZA Deputy Sheriff A. D. TP? 2 0 0 9 HAY i 9 P1 l.;. 05 F ?. -/'d • au, a /`f •a CA- 13(17V(, 41- aa.5,3G9