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Home My WebLink About09-2720 Our File Ito.: 200597 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.D.08423 ' 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. LORI A HIMES 9 WAYNE RD CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: CA - AUO o'-w;t-rem 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 t +d. Our File ?No.: 200597 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. LORI A HIMES 9 WAYNE RD CAMP HILL, PA 17011 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.. 0 9- -2 7 20 C4;;c,l ? - 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 LORI A RIMES, an adult individual residing at 9 WAYNE RD CAMP HILL, PA 17011. 3. Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, is the Assignee and Successor in Interest of Account #5490990997783616; and said account was issued to Defendant(s) by FIA CARD SERVICES, 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 $8,161.73. 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 $8,161.73 and requests this Court award Plaintiff attorney's fees and costs to the extent permitted by applicable law. APOTHAKER &,AS$OCIATES, P.C. A Law Firm Enia-aed in Debt BY: Dated: 4/27/2009 David J. Apothaker, Esquire Our File No.: 200597 -fib VERIFICATION David I 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 el ting to unsworn falsification to authorities. 1-415othaker, Esquire Attorney for Plaintiff DATE: 4/27/2009 PMP~fcr. LORI A HIMES Account Namdar. 5490 9808 1000 2947 July 2008 Statement Credit Line: $7,000.00 Cash of Credit Available: Summary of Transactions B01_ling Cycle and Payment Information Previous Balance $7,743.19 Days in Billing Cycle 29 Payments and Credits - $225.00 Closing Date 07/DI/08 Purchases and Adjustments + 50.90 Periodic Rate Finance Charges + 598.84 Pw;rnent Due Data 07/26/06 Transaction Fee Finance Charges + SD.DO Currant Payment Due $225.00 Past Duut•Arnouht + $0.00 New Balance Total $7,617.03 Total Mermum Paynptll Oue ? Ojos BaekofAmerica 'wIr Call tafr" 1-800.78941865 TOD hearing-impaired I-800-348.3178 MavAn nentala• BANK OF AMERICA P.O. BOX 15726 1NIUdWGTON. DE 18888.5726 MaA'B0wImuklm BANK OF AMERICA P.O. BOX 15026 WILMINGTON. DE i9no-sme nulaFunco Account Pa? ITI•ms arKl Credits - ---°-----.? ??••••? 1i1°°"uvn P ffw PAYMENT r ID Date Date Number Number Amount - -- BY PHONE O(V30 - 225.00 CR t?•xx? 3rftxra G:O?cx? CitJLD?k"6GLTIj AN IMPORTANT AMENDMENT TO YOUR ACCOUNT TERMS IS ENCLOSED. IMPORTANT INFORMATION REGARDING YOUR ACCOUNT. ?41r181'i7r3NJ E?rx![ Romotbnal Category Transaction Types Daly Periodic Rate Cmrw4vondpgAanu& Pbrt,a kywo Rate APR Type BNance Su4wd to Fkume ChAW Balance Transfers 0.043836% Cash Advances 16.0096 T 50.00 0.043838% Purcha 16.00% T $0,00 ses 0.043836% Annual Percentage Rate [or this Billing Period: 16.00% T 57,775.38 (Includes Parodic Rata Finanr» Charges and Transaction Fee Rinance Charges that resub in an APR which exceeds 16.00% the Corresponding APR above.) APR Type Definitions APR Type. T. Temporary APR (APR for special circumstances) 03 0076170300022500000225000005490990810002947 BANK OF AMERICA P.O. BOX 15726 WILMINGTON, DE 19886-5726 III llll,llrIII I rleeleallrrBills lrrll1111loll loll llrl LORI A HIMES 9 WAYNE RD CAMP HILL PA 17011-6663-090 I--l Cheek here for a dance of meano .dear or e-A ..u..hr.A Please povkb as aonvetlons on the averse alde ACCOUNT AVUSEk 5480 99061000 2947 NEWBALANCE TOTAL: $7,617.03 PAYAIENTDUEDA7F 07/26/De ff-p I aye. nes..nwer.. a.r.re Ls c/ieckOr/Yvmy s4N OFA r wraat+ro•eANtroFA,uE/10t I:S240 2 2 2501: IS 93081000294711, 8 N R _ w' i yc ,)F THE CLUBAIN 3 J Fil I:40 lrLl1? ,_ .?I`v1?Ef *79.50 A'>-4' 9to Cv-* 131 Sheriffs Office of Cumberland County R Thomas Kline a+t"t`' et ellVjb?r? f? Edward L Schorpp Sheri' °t Solicitor f. - Ronny R Anderson Jody S Smith Chief Deputy own=? ?? '"` su=FF Civil Process Sergeant SHERIFF'S RETURN OF SERVICE 05/01/2009 08:53 PM - Shawn Harrison, Deputy Sheriff, who being duly sworn according to law, states that on May 1, 2009 at 2053 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Lori A. Himes, by making known unto Rawnell Welsh, Jr., adult in charge, at 9 Wayne Road, Camp Hill, Cumberland County, Pennsylvania, 17011 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $39.70 May 05, 2009 Docket No. 2009-2720 Portfolio Recovery v Lori Himes SO ANSWERS, R TH ASK 7E, SHERIFF c DeAuty Sheriff C C co L l c-n <