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Home My WebLink About08-6875 Our File No.: 187743 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 PALISADES COLLECTION, LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. KELLY BINGAMAN 2250 CANTERBURY DR MECHANICSBURG, PA 17055 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: O$ - (08?5 Civi LTe-rP, 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 ? A Our File No.: 187743 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 PALISADES COLLECTION, LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. KELLY BINGAMAN 2250 CANTERBURY DR MECHANICSBURG, PA 17055 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Dg'_ G f'7 5- Grvi) 4c-t^ 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 KELLY BINGAMAN, an adult individual residing at 2250 CANTERBURY DR MECHANICSBURG, PA 17055. 3. Plaintiff, PALISADES COLLECTION, LLC, is the Assignee and Successor in Interest of Account #7001191118797498; and said account was issued to Defendant(s) by BEST BUY, 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 $1,615.81. 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 $1,615.81 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & S IATES, P.C. BY: A Law Firm Dated: 11/11/2008 David I , Esquire Our File No.: 187743 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 igned understands that the statements therein are made subject to the penalties of 18 Pa.C.S.A. 4904 rela g to worn falsification to authorities. David J. A thaker, Esquire Attorney fbr Plaintiff DATE: 11/11/2008 4 PALISADES COLLECTION, L.L.C. R 9 BINGAMAN,KELLY 2250 CANTERBURY DR MECHANICSBURG, PA 17055 IF ADDRESS AS SHOWN ABOVE IS INCORRECT. PLEASE INDICATE CHANGE BELOW NAME ADDRESS ACCOUNT NUMBER 7001191118797498 DATE 10/08/08 PALISADES FILE NUMBER 5829308 NEW BALANCE 1,427.39 PAYMENT DUE DATE MINIMUM PAYMENT DUE NOW 1,427.39 PLEASE WRITE IN AMOUNT OF PAYMENT ENCLOSED $ PLEASE DETACH AND TOP PORTION WITH YOUR PAYMENT CREDIT CREDIT PAST DUE LIMIT AVAILABLE 0 0 1,427.39 NEW TRANSACTIONS Balance Due 12/22/05 PALISADES COLLECTION, L.L.C. DELAWARE LIMITED LIABILITY CORP. ASSIGNEE OF EMCC, INC. P.O. BOX 1244 ENGLEWOOD CLIFFS, NJ 07632 SUMMARY OF TRANSACTIONS PREVIOUS BALANCE PAYMENTS AND CREDITS $1.427.39 PROMPT CREDITING OF PAYMENTS: TO RECEIVE CREDIT FOR PAYMENT AS OF THE DATE OF RECEIPT. ME MOST RECEIVE THE Top PORTION OF THE STATEMENT AND YOM CHECK OF MONEY ORDER BY 3:00 P.M. AT: PALISADES COLLECTION, L.L.C. P.O. BOX 1244 ENGLEWOOD CLIFFS, NJ 07632 PAYMENTS RECEIVED AT THE ABOVE ADDRESS IN THE MANME2 SPECIFIED AFTER THAT TIME WILL BE CREDITED TO YOUR ACCOUNT AS OF OUR NEXT BUSINESS DAY. THE CREDITING TO YOUR ACCOUNT OF PAYMENTS RECEIVED AT ANY LOCATION OTHER THEN THE ABOVE ADDRESS MAY BE DELAYED OP TO 5 DAYS FROM DATE OF RECEIPT. STATEMENT CLOSING DATE 10/08/08 AMOUNT $1,427.39 NEW BALANCE $1,427.39 PAYMENT DUE DATE MINIMUM PAYMENT DUE NOW 1,427.39 SEND INQUIRIES TO: PALISADES COLLECTION, L.L.C. P.O. BOX 1244 ENGLEWOOD CLIFFS, NJ 07632 TAA File# B321996 State Code APOT ? exa 00 - rn - n 00 1.5 SHERIFF'S RETURN - REGULAR CASE NO: 2008-06875 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PALISADES COLLECTION LLC VS BINGAMAN KELLY KENNETH E. GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BINGAMAN KELLY the DEFENDANT , at 2050:00 HOURS, on the 2nd day of December-, 2008 at 2250 CANTERBURY DR MECHANICSBURG, PA 17055 KELLY BINGAMAN 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: Docketing Service Affidavit Surcharge ; 18.00 9.90 .00 10.00 00 37.90 So Answers: R. Thomas Kline 12/03/2008 APOTHAKE Sworn and Subscibed to By: before me this day of A.D. Our File No.: j 87743 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 PALISADES COLLECTION, LLC Plaintiff, VS. KELLY BINGAMAN Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-6875 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, KELLY BINGAMAN, in the default of an Answer, in the amount of $1,658.98 computed as follows: Amount claimed in complaint: $1,615.81 Amount Paid: - $(0.00) Interest from November 11, 2008 to 05/14/09 at the legal interest rate of 6.000 per annum $43.17 Costs $0.00 Attorney fees $0.00 TOTAL $1,658.98 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, KELLY BINGAMAN, last know address is 2250 CANTERBURY DR MECHANICSBURG, PA 17055. APOTHAKER ASS TES, P.C. Attorne&ys fo 1 ' ff A Law Firm Emme in bt Collection By: David J. Dated: 5/14/2009 .I Our File No. % 187743 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 PALISADES COLLECTION, LLC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff, VS. NO.: 08-6875 KELLY BINGAMAN Defendant. Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND : 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 2250 CANTERBURY DR MECHANICSBURG, PA 17055. We inquired with the web site of the Deft Boulevard, Suite 400, Arlington, VA 22209-2593, if Mary M. Snavely-Dixon, Director of the indicated that the Defendant(s) is/are not in the i David J. Apbthaker Attorney for Plaintiff Data Center, located at 1600 Wilson ) is/are in any branch of the military. Center has sent back our inquiry The above signed understands that the statements herein are made subject to the penalties of 18 Pa. C.S. Section 4904 relating to unsworn falsification to authorities. Dgmrb mnt of Dew Mapower Data Ceder wry Stem Rqx*t Parsim at to the Se?v?cawnembexs Civi Reief'Act A Mwy M. Snm* D oxm% Dieac Department of Ddmse - Manpower Data Center 1600 Wilsc C Salter 400 Arlon, VA 22209-2593 MALY-14-2009 10:10-.39 The Defense N mpmar Data Center (DMDC) an orgammadoo of the Departmwent ofDerffixw 69 mumintaims the Defense Ewobx* and ENSW Reporting Sy*= (DEERS) d ose wbich is the official source ofdalas an cf*k for military medical rare and odw A? systerns. The Department of Defense y supports the a do r of the. ortirem emrs Civl.Re Act [S0 USCS A"m $§ 501 et seq] (SCRA) {farm erly the, Soldie& and Salons' CH RelkfAct of 1940}_ TIC bas issued baadrreds ofthowands of 'does not possess urge r indicating tbet the individual is currmdy an active clnty responses, and has expaimmA a amal arm rate. In the event the dhAdmd referenced above, or my fimly inernber, >rieed, or repres?entetim asserts in any nmmnff that the intfivided is on active duty, or is o&ervwise entitled to the protections of the SCRA, you are srom* encouraged to obtain further won of the pexsae?'s active duty her contacting Bart persods Mlitary Service vim the "de lalr.mr URL provided below. If you have evidence the person is on ac dve>-duty and you fail to obtain this addii tiooaf hK&ly Service cation,, provisions, of the SCRA may be invoked against yon. If you obtain fi rdw akxnmdi r, about the person ( e.g., an SSPI, improved accuracy of DOB, a middle ame). you can emit your request again at this Web site and we w pvv de a new certificate for that query. Jbis xmpoew reflects current active day stem only. For historical irfarammiaa, please contact the Mitry Service SCRA. POINtg- of-contact. Seri; hthm'.flwww na AisPPCWSLDP.JW WARNING Ibis certifficate was provided based on a nm a and Social Security number (SSN} provided by dw rem. Providing an esromeous samme or 5SN w* cause an errcmcoras certificate to be provided. Report .-Up roZ iC. Llpm sewcb mg the boa dam banks ofthe De art t of Ddesae Manpower Data Curter, based an the ioEoeummoa that you per. the sbcm is the curial status of the ikty daat as to aA branches of the illy. 187743 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY PALISADES COLLECTION, LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) KELLY BINGAMAN ) NO. 08-6875 To: KELLY BINGAMAN 2250 CANTERBURY DR MECHANICSBURG, PA 17055 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: January 06, 2009 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 DAVft 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 ' SHERIF'F'S RETURN - REGULAR CASE NO-: 2008-06875 P -t3 COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PALISADES COLLECTION LLC VS BINGAMAN KELLY jtir a KENNETH E. GOSSERT , Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn according to law, says, the within COMPLAINT & NOTICE was served upon BINGAMAN KELLY the DEFENDANT , at 2050:00 HOURS,, on the 2nd day of December_, 2008 at 2250 CANTERBURY DR MECHANICSBURG, PA 17055 by handing to KELLY BINGAMAN 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 9.90 Affidavit .00 Surcharge 10.00 .00 37.90 Sworn and Subscibed to before me this day So Answers: R. Thomas Kline 12/03/20`" APO THAKE By: of I A. D. ,Jl 1C s r 2GC9 , iY 0 Ail 1: 48 *14. oo pn 6rrq c,t,.r 134'1 qol fy* 0,539 0 ., OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: KELLY BINGAMAN 2250 CANTERBURY DR MECHANICSBURG, PA 17055 PALISADES COLLECTION, LLC Plaintiff, VS. KELLY BINGAMAN Defendant. NOTICE COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 08-6875 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, Esg, at this telephone number: 215-634-8920 3/61%9