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Home My WebLink About09-2158Our File No.: 183 703 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. DAVID A BUSKEY 209 MARKET ST NEW CUMBERLAND, PA 17070 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 0q- a15$ O iytl NOTICE You have been sued in court. If you wish to defend against the claims set forth in 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 claims warned that if you fail to do so the case may proceed without you and a judgment may be e without finther notice for any money claimed in the complaint or for any other claim or r 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 t written appearance personally set forth against you. You are ntered 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 Our File No.: 183 703 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. DAVID A BUSKEY 209 MARKET ST NEW CUMBERLAND, PA 17070 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: q_ aISt "- T4 CIVIL ACTION COMPLAINT FIRST COUNT 1. Plaintiff is PORTFOLIO RECOVERY ASSOCIATES, LLC c/o Apothake? & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are DAVID A BUSKEY, an adult individual residing at 209 MARKET ST NEW CUMBERLAND, PA 17070. 3. Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, is the Assignee and Successor in Interest of Account #4479481600456582; and said account was issued to Defendant(s) by WASH11s GTON 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 $7,52761. 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 o the amount due as above. WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against efendant(s) for the sum of $7,527.61 and requests this Court award Plaintiff attorney's Ps ar?d costs to the extent permitted by applicable law. Dated: 3/31/2009 APOTHAKE & SSOCIATES, P.C. Atto ey or Plaintiff A Law Firm ga ed in t Collection BY: David J. Apothaker, Esquire Our File No.: 183703 I "I 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 unders ds that the statements therein made subject to the penalties i of 18 Pa.C.S.A. 4904 relating to unsworn falsification to th rities. I David J.Ap-othaker, Esquire Attorney for Plaintiff DATE: 3/31/2009 •._ y PAYMENT MINIMUM BALANCE AS OF ACCOUNT DUE DATE PAYMENT 1?A520DS NUMBER P.O. Son 110191. DRIM TX "2164410 01AtA6 51,1Se.00 ZS,S47.S2 44794816.0045-LSU blob m - M Addw w Sloe pure tLw wb1s t h1) AMOUNT ENCLOSED (use No or Mock ink) Ad&=: Aar .1A? ????n a? Ckr: Stow: Zo: Y . Haar Plgrr: War p.e.r 000 Make Chwow Payable to Washington Mutual ',.. WASHINGTON MUTUAL CARD SERVICES DAVID A BUSKEY 53M P.O. BOX 860487 208 MARKET ST DALLAS TX 75288.0487 NEW CUMBERLAND PA 17070-2149 4474461600456582 0114400 0564742 0015000103 hePortmd ggeseges YOUR ACCOUNT IS PAST DUE AND OVER ITS CREDIT LIMIT. Pismo pay the minimum Payment rated above song with the overGMt amount Immediately or call us at 1-800.280-9441. Aoeeunt Santteary >he = Stdanwat Data 12/05105 Croft 6 Payments ?,a =0.00 0140 Line :4."0.00 Cash Advsnoas + $0.00 p Available Ondit for Cash Advances as of 1210M $0.00 NEW BALANCE = $5,847.92 22 ME Transactions test Pad Date Dale Dasaip"a" Reference Number - Amount s Dos 01 Decal U1TE PAY W ff CHARGE 0000 .00 EM FOR BILLM ERRORS AND IMPORTANT 81FORUATION, SEE REVERSE SIDE. Balance Category DETACH HERE R EST59111 6N2 0102 Sic 7 IS1Z4S Pep ,1 of 1 S III 532115 Avenge Day Periodic Annual % Finance Ghee Do" Balance Rate RMe (APR) Charges Terns Standard Purchase - Cummt Cycle $3,895.12 .0822X• 29.99%• $102.46 Term A Standard Cash - Cerra Cycle 51,844.36 .0822X' 29.99%' $43.25 Term B ANNUAL PERCENTAGE RATE fla billin g cycle: 31.56% 'These rats mew very. For 244hax Automated Account Inbrms ion, please call 1400-2110-0561 or visa us of awns providliancom Your acoount is bawd by Wm MnBton Mutual Bank, HwWW aen, NV. COI-LH-RL 31972 (11)07) Ql{v 33 PD AI"H co jgg35w*- ,ml Sheriffs Office of Cumberland County R Thomas Kline r of culfth'. Edward L Schorpp Sheriff Solicitor Ronny R Anderson Jody S Smith Chief Deputy OFFICE r ` s"ERIFF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 04/17/2009 10:31 AM - Amanda Cobaugh, Deputy Sheriff, who being duly sworn according to law, states that on April 17, 2009 at 1031 hours, she served a true copy of the within Complaint and Notice, upon the within namec defendant, to wit: David A. Buskey, by making known unto David A. Buskey personally, at 209 Marke¢ Street, New Cumberland, Cumberland County, Pennsylvania, 17070 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $73.90 April 21, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF Deputy Seri Docket No. 2009-2158 Portfolio Recovery v David Buskey C?? ? 'TI . APOTHAKER& ASSOCIATES P.C. �, f Liii?J ` t BY: David J. Apothaker, Esquire B 4 P Attorney I.D.# 38423 18RL� 'Zs Mount Laurel,NJR 080 54 06 pE"rIS YL VAMJA (800) 672-0215 Attorney for Plaintiff PORTFOLIO RECOVERY ) COURT OF COMMON PLEAS ASSOCIATES, LLC ) CUMBERLAND COUNTY ) Plaintiff, ) vs. ) ) NO. 09-2158 DAVID A BUSKEY ) ) Defendant. ) PRAECIPE TO MARK JUDGMENT SATISFIED TO THE PROTHONOTARY: Please mark the Judgment Satisfied against the Defendant. Judgment has been paid in full. APOTHAKER . A`SOCIATES, P.C. Atto -ys f.i Plaintiff A Law Firm E gage' in Debt Collection By: David J. Apot : - , Esquire 11111111 111 111111 111 11 * Q 1 8 3 7 0 3 S S O J 1 - * a ash CLI# 9iô