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` Our File No.: 187388
APOTHAKEA & 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.
LYDIA A MAGNI
84 OLD BARN LN
NEWVILLE, PA 17241-8709
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: IN - 0115'1 0'-"'i (
NOTICE
You have been sued in court. If you wish to defend against the claims set forth it
take action within twenty (20) days after this complaint and notice are served, by entering
or by attorney and filing in writing with the court your defenses or objections to the claim:
warned that if you fail to do so the case may proceed without you and a judgment may be 4
without further notice for any money claimed in the complaint or for any other claim or 1
You may lose money or property or other rights important to you.
YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE. IF YOU
OR CANNOT AFFORD ONE, GO TO OR TELEPHONE THE OFFICE SET FORTH BE
YOU CAN GET LEGAL HELP.
IF YOU CANNOT AFFORD TO HIRE A LAWYER, THIS OFFICE MAY B
WITH INFORMATION ABOUT AGENCIES THAT MAY OFFER LEGAL SERVICES
A REDUCED FEE OR NO FEE.
CUMBERLAND COUNTY BAR ASSOCIATION
2 LIBERTY AVENUE
CARLISLE, PA 17013
717-249-3166
the following pages, you must
j written appearance personally
set forth against you. You are
tered against you by the court
lief requested by the plaintiff.
NOT HAVE A LAWYER
V TO FIND OUT WHERE
ABLE TO PROVIDE YOU
D ELIGIBLE PERSONS AT
Ourlile No.: 187388
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.
LYDIA A MAGNI
84 OLD BARN LN
NEWVILLE, PA 17241-8709
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: 0q- a l 37 ? - ;
CIVIL ACTION COMPLAINT
FIRST COUNT
1. Plaintiff is PORTFOLIO RECOVERY ASSOCIATES, LLC c/o
Fellowship Road C306, Mount Laurel, NJ 08054.
2. Defendant(s) is/are LYDIA A MAGNI, an adult individual residing at 84
PA 17241-8709.
3. Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, is the
Account #5407915016479765; and said account was issued to Defendant(s) by
creditor.
& Associates, P.C., 520
BARN LN NEWVILLE,
and Successor in Interest of
HOUSEHOLD, the Original
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 $2,571 ?32. 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
Exhibit "A".
7. Although demand has been made, Defendant(s) has failed to make payment (
WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against
$2,571.32 and requests this Court award Plaintiff attorney's fees and costs to the extent
BY.
David J. Apothaker, Esquire
Dated: 3/31/2009
APOTHAKER AS OCIATES, P.C.
Attorn for laintiff
A Law Firm Eng gV Collection
account and are included in
the amount due as above.
s) for the sum of
by applicable law.
Our File No.: 187388
VERIFICATION
David J. Apothaker, Esquire hereby states that I am counsel for plaintiff in this action, and
Verification, and that the statements made in the foregoing Civil Action Complaint are trt
knowledge, information, and belief. The undersigned understands that the statements therein
of 18 Pa.C.S.A. 4904 relating to unsworn falsification to au riti s.
David J. Apothaker, Esquire
Attorney for Plaintiff
I am authorized to take this
and correct to the best of my
made subject to the penalties
DATE: 3/31/2009
•' PORTFOLIO RECOVERY ASSOCIATES, LLC
LYDIA A MAGNI
84 OLD BARN LN
NEWVILLE, PA 17241-8709
STATEMENT OF ACCOUNT
Debtor's Name: LYDIA A MAGNI
Account Number: 5407915016479765
Original Creditor: HSBC HOUSEHOLD
Balance Due: $2,571.32
Our File No.: 187388
EXHIBIT "A"
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Sheriffs Office of Cumberland County
R Thomas Kline t,, at cuiribrr/ t Edward L Schorpp
Sheriff Solicitor
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Ronny R Anderson Jody S Smith
Chief Deputy OFFICE =' ',_ ?-?ERlrr Civil Process Sergeant
SHERIFF'S RETURN OF SERVICE
04/09/2009 07:22 PM - Dennis Fry, Deputy Sheriff, who being duly sworn according to law, states that on April 9, 200E
at 1922 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Lydia A. Magni, by making known unto Lydia A. Magni personally, at 84 Old Barn Lane,
Newville, Cumberland County, Pennsylvania, 17241, its contents and at the same time handing to her
personally the said true and correct copy of the same.
SHERIFF COST: $37.00
SO ANSWE S,
eo--01 Z?p 0 0 e
April 13, 2009
Docket No. 2009-2157
Portfoloio Recovery v Lydia Magni
R THOMAS KLINE, SHERIFF
Dep y Sheri.
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