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Home My WebLink About09-0675Our File No.: 170679 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. JULIE D LEHMAN-LINDSAY 109 WOODVIEW DR MOUNT HOLLY SPRINGS, PA 17065 Defendant. COURT OF COMMON PLEAS CUMBERLAND COU0'i"it TY NO.. M- (p'75 I erN, 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.: 170679 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. ) JULIE D LEHMAN-LINDSAY ) 109 WOODVIEW DR ) MOUNT HOLLY SPRINGS, PA 17065 ) Defendant. ) COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 0q- 67S &-a - 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 JULIE D LEHMAN-LINDSAY, an adult individual residing at 109 WOODVIEW DR MOUNT HOLLY SPRINGS, PA 17065. 3. Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, is the Assignee and Successor in Interest of Account #4185865639747422; 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 $2,626.13. 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". . I above. 7. Although demand has been made, Defendant(s) has failed to make payment of the amount due as WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of $2,626.13 and requests this Court award Plaintiff and costs to the extent permitted by applicable law. .C. A Law Firm F BY: David J. Dated: 1/26/2009 in 130t Collection Esquire Our File No.: 170679 "a 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 J. A'P-othaker, Esquire Attorney for Plaintiff DATE: 1/26/2009 .y . O O x O O N .. .o v v N N v v N ?p to OD 01 ON 0 00 co O ak O to N MM? _V G P) ct a .0 0 cn o x H 0 %D 0 r N N C Ul F4 M %D z w Erl H H Erl ro N 0 01 Ul O H la- 0 P- CT m a a rr a En 0 o x to r •• R H f 3? tai 0 f x 0 r r 1-' r H Ul P4 W t:j H ? z v ro ? N v 01 0 O N 00 m N ro 0 ro O r fZ N H Cl .0 p p C4 w w o H o w ak z m 00 H H H n x e? r r Irt? W O n W O N W d N V2 w rotvo 0 n 7 H tM H H N bd 0 pq H H H H z a I • ' Providian t' P. 0. Box 160633, Dsau. TX 75206-0433 0Indicats change of addraes on back WASHINGTON MUTUAL CARD SERVICES P.O. BOX 660467 DALLAS TX 75266-0487 111s111111111111111u111nl1n 1111111111111111111111111111111 Payment Minimum Balance as of Account Due Dab Payment 1025/2006 Number 11/21/06 6612.00 $2250.06 4185-86"747422 AMOUNT ENCLOSED lose blue er black ink) $ ?DDDD. DD N 000 Make Cheeks Payable to Washington Mraual JULIE D LEHMANUNDSAY 13360 109 WOODVIEW DR MOUNT HOLLY SPRINGS PA 17065.2002 111111111 111 1111111/1181 111111111111111 11111 111 111 4185865639747422 0061200 0225005 0010000 27 1 ..e 6092 0422 .lrG4 1 7 27 061025 PACE 1 of 1 COLR2042 N000 wig DETACH HERE OIAB6092 13360 mportant Messages YOUR ACCOUNT IS PAST DUE AND OVER ITS CREDIT LINE. Please pay the minimum payment listed above along Mth the ovedimk amount immediate) or call us at 1-600-280.9441. 4P- Account Number 4185-8656-3974.7422 Previous Balance $2 194 46 Statement Closing Date 10125/06 Credits & Payments - , . $0.00 Minimum Payment of $612.00 due try 11121/06 Purchases & Other Charges + $0.00 Credit Line $1,531.00 Cash Advances + $0 00 Available Credit Line as of 10125/06 $0.00 FINANCE CHARGE + . $55.59 Available Credit for Cash Advances as of 10/25/06 $0.00 NEW BALANCE - - $2 250 05 Days in Current Billing Cycle 29 , . Transactions Date Description Amount Balance Category 1 Average Dally PeriodbC Corresponding Flnance Grace Daly Balance Rate APR Charges Terms Purchase - Current cycle >;2,221.17 .08631.` 31.49%• $55.59 Term A Cash - Current Cycle $0.00 .0963X; 31.49%• $0.00 Term B Effectlw ANNUAL PERCENTAGE RATE (APR); 30.039x. 'These rates may vary. The Corra n e Charges is the rda of interest you pay when you as" a balance ce Pumhaesa or main advances. The Elhcsve APR represents YW total finance e- incdudn aludirg traneae0al Tees such as Cash advance and balance transfer fees, - expressed as a Percentage. For 24-hour Automated Account information, please can 14800-2804)561 or vises us at www.providian.com Your account is Issued by Washington Mutual Bank, Henderson, NV. 33976 (03107) NMN0002 00 L 7 3 t-r7 -n Fri -ry N y GJ .Xl C SHERIFF'S RETURN - REGULAR CASE NO: 2009-00675 P COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PORTFOLIO RECOVERY ASSOCIATES VS LEHMAN-LINDSAY JULIE D 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 LEHMAN-LINDSAY JULIE D the DEFENDANT , at 0019:16 HOURS, on the 11th day of February-, 2009 at 109 WOODVIEW DR MOUNT HOLLY SPRINGS, PA 17065 by handing to TODD LINDSAY HUSBAND OF DEFENDANT 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 So Answers: Service 5.40 Affidavit .00 Surcharge 10.00 R. Thomas Kline .00 33.40 02/12/2009 APOTHAKER & ASSOCIATES Sworn and Subscibed to before me this By: day of A. D. t? N r rTI y- rn C j Our File Nc,.: 170679 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker Attorney I.D.# 3 8423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 FUKI tUL1U KEC;UVERY ASSOCIATES, LLC Plaintiff, vs. JULIE D LEHMAN-LINDSAY Defendant. Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-675 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, JULIE D LEHMAN-LINDSAY, in the default of an Answer, in the amount of $2,668.56 computed as follows: Amount claimed in complaint: $2,626.13 Amount Paid: - $(0.00) Interest from January 26, 2009 to 05/14/09 at the legal interest rate of 6.000 per annum $42.43 Costs $0.00 Attorney fees $0.00 TOTAL $2,668.56 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, JULIE D LEHMAN-LINDSAY, last know address is 109 WOODVlEW DR MOUNT HOLLY SPRINGS, PA 17065. APOTHAK4eysPlea?' IA S, P.C. Attiff A Law Firm t Collection By. David J. Apothaker Dated: 5/14/2009 Our File No.: 170679 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 vs. Plaintiff, JULIE D LEHMAN-LINDSAY Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-675 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 Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 109 WOODI HOLLY SPRINGS, PA 17065. We inquired with the web site of the Defense anpower Data Center, Boulevard, Suite 400, Arlington, VA 22209-2593, if tl fendant(s) is/are in any Mary M. Snavely-Dixon, Director of the De ns Manpower Data Center has sent indicated that the Defendant(s) is/are not in the mil' David Apothaker Attorney Toy-Plainti The above signed understands that the statements herein are made subject to the penal Section 4904 relating to unsworn falsification to authorities. the attorney for N DR MOUNT 1 at 1600 Wilson of the military. our inquiry of 18 Pa. C.S. Request for Military Status Department of Defense Manpower Data Center Militar y Status Report Pursuant to the Servicemembers Civil Relief Act Page 1 of 1 MAY-14-2009 09:49:06 Last Name First/Middle Begin Date Active Duty Status Service Agency LEITMAN JULIE Based on the information you have furnished, the DMDC do information indicating that the individual is currently on acti s not possess any e duty. Upon searching the information data banks of the Department of Defense Manpower Data C nter, based on the information that you provided, the above is the current status of the individual as to all branc es of the Military. Aaut f #1 44, Af??_ Mary M. Snavely-Dixon, Director Department of Defense - Manpower Data Center 1600 Wilson Blvd., Suite 400 Arlington, VA 22209-2593 The Defense Manpower Data Center (DMDC) is an organization of the Department of Defen the Defense Enrollment and Eligibility Reporting System (DEERS) database which is the off data on eligibility for military medical care and other eligibility systems. The Department of Defense strongly supports the enforcement of the Servicemembers Civil USCS Appx. §§ 501 et seq] (SCRA) (formerly the Soldiers' and Sailors' Civil Relief Act of 1 issued hundreds of thousands of "does not possess any information indicating that the indivk active duty" responses, and has experienced a small error rate. In the event the individual refE any family member, friend, or representative asserts in any manner that the individual is on a otherwise entitled to the protections of the SCRA, you are strongly encouraged to obtain furt. the person's active duty status by contacting that person's Military Service via the "defenselir provided below. If you have evidence the person is on active-duty and you fail to obtain this Military Service verification, provisions of the SCRA may be invoked against you. that maintains rl source of ;lief Act [50 10). DMDC has al is currently on mced above, or ive duty, or is ;r verification of ,mil" URL If you obtain further information about the person ( e.g., an SSN, improved accuracy of DOB, a middle name), you can submit your request again at this Web site and we will provide a new certificate for t) at query. This response reflects current active duty status only. For historical information, please Service SCRA points-of-contact. See: http://www.defenselink.mil/faq/pis/PC09SLDR.html WARNING: This certificate was provided based on a name and Social Security number (S requester. Providing an erroneous name or SSN will cause an erroneous certificate to be pr Report ID: BBISYUEXFYE the Military provided by the https://www.dmde.osd.mil/scra/owa/scra.prc_Select 5/14/2009 170679 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY PORTFOLIO RECOVERY ASSOCIATES, LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY vs. ) JULIE D LEHMAN-LINDSAY ) NO. 09-675 To: JULIE D LEHMAN-LINDSAY 109 WOODVIEW DR MOUNT HOLLY SPRINGS, PA 17065 i NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: March 04, 2009 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITIN WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORT AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARIN AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, F YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FOR H BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING LAWYER. IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MA BE ABLE TO PROVIDE YOU WITH INFORMATION ABOUT AGENCIES THAT AY OFFER LEGAL SERVICES TO ELIGIBLE PERSONS AT A REDUCED FEE OR NO FE . CUMBERLAND COUNTY BAR ASSOCIATION 2 LIBERTY AVENUE CARLISLE, PA 17013 717-249-3166 DAVIDV. APOTHAKER, ESQUIRE APOTHAKER & ASSOCIATES, PC A Law Firm Engaged in Debt Collectic 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff Attorney ID #38423 CASE NO: 2009-00675 P SHERIFF'S RETURN - REGULAR COMMONWEALTH OF PENNSYLVANIA: COUNTY OF CUMBERLAND PORTFOLIO RECOVERY ASSOCIATES VS LEHMAN-LINDSAY JULIE D KENNETH E GOSSERT Sheriff or Deputy Sheriff of Cumberland County,Pennsylvania, who being duly sworn accordi?g to law, says, the within COMPLAINT & NOTICE was served upon LEHMAN-LINDSAY JULIE D the DEFENDANT , at 0019:16 HOURS, on the 11th day of Februaty , 2009 at 109 WOODVIEW DR MOUNT HOLLY SPRINGS, PA 17065 by handing to TODD LINDSAY HUSBAND OF DEFENDANT a true and attested copy of COMPLAINT & NOTICE toge and at the same time directing His attention to the contents Sheriff's Costs: Docketing Service Affidavit Surcharge So Answers: 18.00 5.40 .00 10.00 R. Thomas Kline .00 33.40 02/12/2009 APOTHAKER & ASSOCIATES Sworn and Subscibed to before me this of By: day r A. D. r r with thereof. FILED-?,,?;;C'IE rJF HE P: THE -'NOTARY 2009 JUN 26 PM 2: 1 a t'&ATlcww&-I,?A 414 . oo Po AT Y CK:# p38Iol Io ?.TT oula9 8 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: JULIE D LEHMAN-LINDSAY 109 WOODVIEW DR MOUNT HOLLY SPRINGS, PA 17065 PORTFOLIO RECOVERY ASSOCIATES, LLC Plaintiff, vs. JULIE D LEHMAN-LINDSAY Defendant. COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-675 Civil Action NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a 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 ARBITRATO 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 Esc. at this telephone number: 215-634-8920 /s/",e.[0, a '5K8 has been &/14/07