The URL can be used to link to this page

Home My WebLink About09-2719A Our File No.: 200578 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. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: OR - 0'!'1!4 0';V;1-FerW' JESSICA ANN RICHARD 1107 YVERDON DR APT B4 CAMP HILL, PA 17011 Defendant. 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.: 200578 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. JESSICA ANN RICHARD 1107 YVERDON DR APT B4 CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: Or' - ,2 ? / 9 0,jLj -7Z- 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 JESSICA ANN RICHARD, an adult individual residing at 1107 YVERDON DR APT B4 CAMP HILL, PA 17011. 3. Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, is the Assignee and Successor in Interest of Account #5140210002936982; and said account was issued to Defendant(s) by BARCLAYS 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 $6,961.42. 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". 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 $6,961.42 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER & A$TCIATES, P.C. A Law Firm Endged iah Debt BY: Dated: 4/27/2009 David J. A'Udtraaker, Esquire Our File No.: 200578 L > 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 relafiiig-t4 unworn falsification to authorities. David J. Aer, Esquire Attorney for Plaintiff DATE: 4/27/2009 PORTFOLIO RECOVERY ASSOCIATES, LLC JESSICA ANN RICHARD 1107 YVERDON DR APT B4 CAMP HILL, PA 17011 STATEMENT OF ACCOUNT Debtor's Name: JESSICA ANN RICHARD. Account Number: 5140210002936982 ` Original Creditor: BARCLAYS BANK Balance Due: $6,961.42 Our File No.: 200578 EXHIBIT "A" CJ OF T-7 209A? X30 Fl !:u3 C!! s'- .?h8. w pa AT'f Ck* 13ig14 Sheriffs Office of Cumberland County R Thomas Kline ','Ookt of `rif?irr?7 Edward L Schorpp Sheri Solicitor Ronny R Anderson Jody S Smith Chief Deputy QFFICF. ?F r- ERiFr Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05/02/2009 10:25 AM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on May 2, 2009 at 1025 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Jessica Ann Richard, by making known unto Jessica Ann Richard personally, at 1107 Yverdon Drive, Apt. B4, Camp Hill, Cumberland County, Pennsylvania, 17011 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $41.50 May 06, 2009 SO ANSWERS, R THOMAS KLINE, SHERIFF z4exzl--?- uty Sheriff Docket No. 2009-2719 Portfolio Recovery v Jessica Richard N C° cC= Fri yYCJ f by