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Home My WebLink About08-6873Our File No.: 152361 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.#38423 52p 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. RACHEL N GRUNDON 618N2NDST LEMOYNE, PA 17043-1002 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: b8 - !o8'I3 Civ i l Tee 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.: 152361 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. RACHEL N GRUNDON 618 N 2ND ST LEMOYNE, PA 17043-1002 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: or, 6?13 r-0 -fay 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 RACHEL N GRUNDON, an adult individual residing at 618 N 2ND ST LEMOYNE, PA 17043-1002. 3. Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, is the Assignee and Successor in Interest of Account #4791070122245796; and said account was issued to Defendant(s) by COLUMBUS BANK AND TRUST, 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 $3,593.97. 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 $3,593.97 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER &SSq)CIATES, P Attorne for Illaintiff / A Law Firm BY: Dated: 11/11/2008 David J. Apoiaker, Esquire Our File No.: 152361 M 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. The undersigned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 rela4 unworn falsification to authorities. David J. , Esquire Attorney for DATE: 11/11/2008 ?.. , 1- 10. , - I , RACHEL N GRUNDON 618N2NDST LEMOYNE, PA 17043-1002 STATEMENT OF ACCOUNT PORTFOLIO RECOVERY ASSOCIATES, LLC Debtor's Name: RACHEL N GRUNDON Account Number: 4791070122245796 Original Creditor: COLUMBUS BANK AND TRUST Balance Due: $3,593.97 Our File No.: 152361 EXHIBIT "A" ? 40 ._ ?'' ? V l v C7 ? c:a O ? <: ` °' ? r { • - c? •? crt _?? .. ?. ?, ??, . _ ? -v ? ? `? ' t ' i~ n SHERIFF'S RETURN - NOT FOUND CASE NO: 2008-06873 P COMMONTWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND PORTFOLIO RECOVERY ASSOCIATES VS GRUNDON RACHEL N R. Thomas Kline Sheriff or Deputy Sheriff, who being duly sworn according to law, says, that he made a diligent search and inquiry for the within named DEFENDANT GRUNDON RACHEL N but was unable to locate Her in his bailiwick. He therefore returns the COMPLAINT & NOTICE NOT FOUND , as to the within named DEFENDANT GRUNDON RACHEL N 618 N 2ND ST WORMLEYSBURG, PA 17043-1002 PER GRANDMOTHER, DEFENDANT DOES NOT LIVE AT THIS ADDRESS. WORKS AT TEXAS ROADHOUSE IN UNION DEPOSIT IN HARRISBURG. Sheriff's Costs: So answer - -? 1 - " Docketing 18.00 Service 15.30 Affidavit .00 R. Thomas Kline Surcharge 10.00 Sheriff of Cumberland County Not Found ?} 5.00 ? ?,?,/,510k " V 4 8.30 APOTHAKER & ASSOCIATES 12/10/2008 Sworn and Subscribed to before me this day of , A.D. S a Our File No.: 152361 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. COURT. OF COMMON PLEAS CUMBERLAND COUNTY RACHEL N GRUNDON NO.: 08-6873 Defendant. PRAECIPE -TO REINSTATE COMPLAINT - CIVIL ACTION TO THE PROTHONOTARY: Kindly reinstate the Complaint in the above captioned Civil Action for an additional thirty (30) days. APOTHAKER & TES, P.C. Attorney ?Sn or Pl ntiff A Law Firm Eng ed ' ebt Coll on BY: David J. Apothaker, Esquire Dated: 12129/2008 c? Q Zo -ALL' Le- -IA a c n SHERIFF'S RETURN - REGULAR CASE NO: 2008-06873 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PORTFOLIO RECOVERY ASSOCIATES VS GRUNDON RACHEL N NOAH CLINE , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon GRUNDON RACHEL N the DEFENDANT , at 2029:00 HOURS, on the 20th day of January , 2009 at TEXAS ROADHOUSE 1101 LOWER ALLEN DRIVE CAMP HILL, PA 17011-1002 RACHEL N GRUNDON 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. T1 Sheriff's Costs: Docketing 18.00 Service 26.10 Affidavit .00 Surcharge 10.00 .00 54.10 Sworn and Subscibed to before me this day So Answers: s ,. R. Thomas Kline 01/21/2009 APOTHAKER & ASSOCIATES By: Deputy m Sheriff of A. D. C°W? `? e >.r? f...? --? F'?=F ? i ` ? . lf,Y .. ?„ 'r . . Our File No.: 152361 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 PORTFOLIO RECOVERY ) ASSOCIATES, LLC ) Plaintiff, ) vs. ) RACHEL N GRUNDON ) Defendant. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO. 08-6873 PRAECIPE TO DISMISS WITHOUT PREJUDICE TO THE PROTHONOTARY: Kindly dismiss this action without prejudice. APOTHAKER & ASSOCIATES, P.C. Attorneys fo aintiff A Law Firm Eng d i Debt Collection By: David J. Apothaker, Esquire Dated: May 22, 2009 FILES r r: OF THE 2099 JUN -2 N 8. 18 Sri! ! ; V