HomeMy WebLinkAbout09-4554Our File No.: 208850
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
ATLANTIC CREDIT & FINANCE INC.
ASSIGNEE FROM HSBC
c/o Apothaker & Associates, P.C.
520 Fellowship Road C306
Mount Laurel, NJ 08054
Plaintiff,
VS.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.. Q9 _ ysS5q Ctv?l-Ferm
AMANDA D DAVIS
309 VALLEY RD
SUMMERDALE, PA 17093
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.: 208850
APOTHAKER & ASSOCIATES, P.C.
BY: David J. Apothaker, Esquire, Esq.
Attorney I.D.438423
520 Fellowship Road C306
Mount Laurel, NJ 08054
(800) 672-0215
Attorneys for Plaintiff
ATLANTIC CREDIT & FINANCE INC
ASSIGNEE FROM HSBC
c/o Apothaker & Associates, P.C.
520 Fellowship Road C306
Mount Laurel, NJ 08054
Plaintiff,
vs.
AMANDA D DAVIS
309 VALLEY RD
SUMMERDALE, PA 17093
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.: 09 - y Ssy Ct..v-d 7i-
CIVIL ACTION COMPLAINT
FIRST COUNT
1. Plaintiff is ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC c/o Apothaker
& Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054.
2. Defendant(s) is/are AMANDA D DAVIS, an adult individual residing at 309 VALLEY RD
SUMMERDALE, PA 17093.
3. Plaintiff, ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC, is the Assignee
and Successor in Interest of Account 46011380010750636; and said account was issued to Defendant(s) by
HSBC, 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 $3,020.64. 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 of the amount due as
above.
WHEREFORE, Plaintiff demands judgment in favor of Plaintiff and against Defendant(s) for the sum of
$3,020.64 and requests this Court award costs to the extent permitted by applicable law.
APOTHAKER & ASSO IATES, P.C.
Attorney, fo 1 ' tiff
A Law Firm Enga d in ebt Collection
BY:
Dated: 7/2/2009
David J.
Our File No.: 208850
VERIFICATION
0OUP,BnU Vii. Qni if hereby states that I am
_6 i ,ipd06-mPS? phi yp for Plainti ff in this action, and that I an 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.SA 4904 relating to unswom falsification to authorities.
Of?1L?
Plaldfff
DATE:
ATLANTIC CREDIT & FINANCE INC. ASSIGNEE FROM HSBC
AMANDA D DAVIS
309 VALLEY RD
SUMMERDALE, PA 17093
STATEMENT OF ACCOUNT
Debtor's Name: AMANDA D DAVIS
Account Number: 6011380010750636
Original Creditor: HSBC
Balance Due: $3,020.64
Our File No.: 208850
EXHIBIT "A"
FILE l ,, F
OF THE
2C0 ' J!JIL -8 P, I: 34
4'18.50 PD q`r'l`I
Sheriffs Office of Cumberland County
R Thomas Kline Fil cD-!
Sheriff
Ronny R Anderson
Chief Deputy { 2? G' ?1
o t ;r ..
Jody S Smith
Civil Process Sergeant og E ;,F -HE s-MFF
Edward L Schorpp
Solicitor
Atlantic Credit & Finance Inc. Assignee from HSBC Case Number
vs.
Amanda D. Davis 2009-4554
SHERIFF'S RETURN OF SERVICE
07/10/2009 04:44 PM - R. Thomas Kline, Sheriff, who being duly sworn according to law, states that he made a
diligent search and inquiry for the within named defendant to wit: Amanda D. Davis, but was unable to
locate her in his bailiwick. He therefore returns the within Complaint and Notice as not found as to the
defendant Amanda D. Davis. Justin Davis defendants ex-husband has advised Amanda D. Davis's
current address is 7455 Paxton Street Harrisburg, PA.
SHERIFF COST: $47.40 SO ANSWERS,
July 13, 2009 R THOMAS KLINE, SHERIFF