HomeMy WebLinkAbout08-6213Our, File No.: 146415
Ay6THAKER & 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. )
ANN CRESSLER )
7 ESSEX ROAD )
CAMP HILL, PA 17011 )
Defendant. )
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: 08 - Lo0113 C' ivi (Terw
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.: 146415
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.
ANN CRESSLER
7 ESSEX ROAD
CAMP HILL, PA 17011
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: 0 _ G 13 c-;,,' 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 ANN CRESSLER, an adult individual residing at 7 ESSEX ROAD CAMP
HILL, PA 17011.
3. Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, is the Assignee and Successor in
Interest of Account #4559907114966529; and said account was issued to Defendant(s) by WASHINGTON
MUTUAL BANK, 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 $4,507.24. 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
$4,507.24 and requests this Court award Plaintiff attorneys f s and costs to the extent permitted by applicable law.
APOTH)tR AS CIATES, P.C.
Attorn for Po A Law Firm En ed t Col
lection
BY:
Dated: 10/8/2008
David J. Apo er, Esquire
Our File No.: 146415
. 1
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. a undersigned understands that the statements therein are
made subject to the penalties of 18 Pa.C.S.A. 49 relat g to uns/ falsification to authorities.
David J. Apothaker, Esquire
Attorney for Plaintiff
DATE: 10/8/2008
ANN CRESSLER
7 ESSEX ROAD
CAMP HILL, PA 17011
PORTFOLIO RECOVERY ASSOCIATES, LLC
STATEMENT OF ACCOUNT
Debtor's Name: ANN CRESSLE
Account Number: 4559907114966 29
Original Creditor: WASHINGTON UAL BANK
Balance Due: $4,507.24
Our File No.: 146415
EXHIBIT "A"
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SHERIFF'S RETURN - REGULAR
CASE NO: 2008-06213 P
COMMONWEALTH OF PENNSYLVANIA:
COUNTY OF CUMBERLAND
PORTFOLIO RECOVERY ASSOCIATES
VS
CRESSLER ANN
KENNETH E GOSSERT
Sheriff or Deputy Sheriff of
Cumberland County,Pennsylvania, who being duly sworn according to law,
says, the within COMPLAINT & NOTICE
CRESSLER ANN
was served upon
the
DEFENDANT , at 0013:07 HOURS, on the 23rd day of October , 2008
at 7 ESSEX ROAD
CAMP HILL, PA 17011 by handing to
ANN CRESSLER
DEFENDANT
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
Service
Affidavit
Surcharge
161,1 P/68
18.00
14.00
.00
10.00
.00
? 42.00
Sworn and Subscibed to
before me this
day
of
So Answers:
R .' Thomas K in
10/24/2008
APOTHAKER & ASSOCIATES
By: 4e"?; J
Dpuy Fier ff
A.D.