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Home My WebLink About09-5688Our File No.: 215293 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. DORETHA L WOODS 400 6TH ST NEW CUMBERLAND, PA 17070 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: N - 5(088 0'iyz(-T?irr' 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.: 215293 APOTHAKEF, & 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. DORETHA L WOODS 400 6TH ST NEW CUMBERLAND, PA 17070 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 6 9- SG P f Cc. .! ' % u- 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 DORETHA L WOODS, an adult individual residing at 400 6TH ST NEW CUMBERLAND, PA 17070. 3. Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, is the Assignee and Successor in Interest of Account #4465611000699185; and said account was issued to Defendant(s) by WASHINGTON 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 $4,335.10. 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 $4,335.10 and requests this Court award costs to the extent permitted by applicable law. APOTHAKE SSOCIATES, P.C. Atto ey r Plaintiff llection A Law Firm E r7 BY: David J. Apothaker, Esquire Dated: 8/10/2009 Our File No.: 215293 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 relating-tp unworn falsification to authorities. David J\Apothaker, Esquire Attorney for Plaintiff DATE: 8/10/2009 PORTFOLIO RECOVERY ASSOCIATES, LLC DORETHA L WOODS 400 6TH ST NEW CUMBERLAND, PA 17070 STATEMENT. OF ACCOUNT Debtor's Name: DORETHA L WOODS Account Number: 4465611000699185 Original Creditor: WASHINGTON MUTUAL BANK Balance Due: $4,335.10 Our File No.: 215293 EXHIBIT "A" G) FlED-)?:rICE OF THc PROTHONOTARY 2009 AUG {7 PM 3* 57 CuM?ll} -lL.-;' 4 $,Iszo PD A7r4 c?? t??ass ex's' aa93o9 Sheriffs Office of Cumberland County R Thomas Kline FLED - -l"F CE }_ 7 r^fr,irlT/??Y Sheriff OF THEE i?cr o1u+n?j??? Chief Deputy Anderson 2009 AUG 28 PH 12: 51 17 Jody S Smith , . Civil Process Sergeant OFFICE Q T,e SrERIFF CUM--, j hV Edward L Schorpp Solicitor Portfolio Recovery Associates, LLC vs Case Number . Doretha L. Woods 2009-5688 SHERIFF'S RETURN OF SERVICE 08/24/2009 07:27 PM - William Cline, Deputy Sheriff, who being duly sworn according to law, states that on August 24, 2009 at 1927 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Doretha L. Woods, by making known unto herself personally, at 400 6th Street New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to her personally the said true and correct copy of the same. SHERIFF COST: $43.30 SO ANSWERS, August 25, 2009 R THOMAS KLINE, SHERIFF TZ, Deputy Sheriff Our File No.: 215293 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff PORTFOLIO RECOVERY ASSOCIATES, LLC Plaintiff VS. DORETHA L WOODS Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-5688 Civil Action PRAECIPE FOR DEFAULT JUDGMENT TO THE PROTHONOTARY: Kindly enter judgment against Defendant, DORETHA L WOODS, in the default of an Answer, in the amount of $4,386.43 computed as follows: Amount claimed in complaint: $ 4,335.10 Less: Amount Paid: ( 0.00) Plus: Interest from August 10, 2009 to October 30, 2009 at the legal interest rate of 6.00% per annum 51.33 Attorney fees _ 0.00 TOTAL $ 4,386.43 I certify that Defendant, DORETHA L WOOD 41t known address is 400 6TH ST NEW CUMBERLAND, PA 17070. David J. Baker, Esq. Attorney for Plaintiff Dated: October 30, 2009 Our File No.: 215293 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff PORTFOLIO RECOVERY ASSOCIATES, LLC COURT OF COMMON PLEAS OF CUMBERLAND COUNTY Plaintiff vs. DORETHA L WOODS Defendant NO.: 09-5688 Civil Action CERTIFICATION PURSUANT TO RULE 237.1 Pursuant to PA Rule Civil Procedure 237. 1, I certify that a copy of the NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT has been sent to the Defendant or the Attorney of Record. I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. Dated: October 30, 2009 i Aso Our File No.: 215293 APOTHAKER & ASSOCIATES, P.C. By: David J. Apothaker Attorney I.D.# 38423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff PORTFOLIO RECOVERY ASSOCIATES, LLC Plaintiff vs. DORETHA L WOODS Defendant Civil Action AFFIDAVIT OF NON-MILITARY SERVICE COMMONWEALTH OF PENNSYLVANIA COUNTY OF CUMBERLAND SS. David J. Apothaker, being duly sworn according to law, deposes and says that I am the attorney for Plaintiff, and authorized to make this affidavit; that Defendant(s) resides at 400 6TH ST NEW CUMBERLAND, PA 17070. We inquired with the web site of the Defense Manpower Data Center, located at 1600 Wilson Boulevard, Suite 400, Arlington, VA 22209-2593, if the Defendant(s) is/are in any branch of the military. Mary M. Snavely-Dixon, Director of the Defens anower Data Center has sent back our inquiry indicated that the Defendant(s) is/are not in e mil ary. David J. Ap fer' Attorney for Plaintiff COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-5688 I verify that the statements made in this Certification are true and correct. I understand that false statements herein are made subject to the penalties of 18 Pa.C.S.A. §4904, relating to unsworn falsification to authorities. M• DepiatmedofDe£eiase Manpower Data Cater {let-34-244947:3&57 iMwitary Stators Report t Purima t to fhe Service Nlembe'< CH >tAdh +t. Lod Ftrsti33l4& Aazir Dale Actire Daly S Was Arfw a Daty Led Ditto Service Name Apace tl Qi7L7S DORETIL Rased ,w t},e vit,xtnation v n hPT Rtrta IPA de L)I WC does nca yes>c;s sin amf'uvum'Nm L mating the i m*idaal sta=re Upon stagy dim 6e itfotma0aa data banks of the Department of Die lMaVower D Cs r, based on the i yaa provided, the abcn a the cttreut stados Qi die iatdnixiuat to aA bm:hn Q(dle I F formed Ser%icaes (Army, Navy, tM rkm Carps, Air Force, 3`y OAA, Pribkc Htauh, and Coast Guard). rte ,.A . Mary Id- SrtavTly-Ditcoa, Dkeator Departmat of Ddemse -'Ma dpower Dada Cuter 1644 Wilsaod Wei, Smite 444 Atfrtgtoo, IVA 22209-21,93 The Defeasr AAtagxwvs r Deft Cam (DNU>C) is art orgawadim oftim Deparmea of Defit s+e dw ma"M ' tAe' e Euralmed and Eipliitr Rxpar" System OXERS) database which is the afbaat source >of thda art c.6gtW for tud'tarr medical ewe and other tligibkt systerm. The DaD strap si;scuts ihe enforcemead af"the ServiceNIrmbers Cir'd Rdrf Act (50 USC App. §& xt}I et sr% as au> ) (SCRA) (fbtmerh' knm n as the Soldiers' and Swk"' Citd Rektf'Aet of 3944). D-C has issvied huudrrds c(Ormands of 'daes to possess any iiaf that the indrvidttd is ewetrtty on ace m respatset, and has eked a sma& amr rate, la the event the individW ref d aba%t, sx myfu* membez, or rrpresrtaatiSr asserts is my'taaeaxrthat the ittrfiv is all WWt t duty, as is a$f[r4a't#C rmtilftd to &e ptoktfiaw of doe SCRA, yvu we **a* eax umged to o@taat fitttkaer v an oftbe pessan s stater by mftcdq that persoa's Sraavke via the' =T L'RL %3vrv c i far}£ts A SL If }sou W-- evidence Ow pezsm its cc active shay Md puled to gbmia *s admatud Sawa v'tritBCatica pueirisr? prs vwcus d the SCRA may be nv and agaeist you. See 50 L'SC App. §321(c). tibuua a else persou {c. SSrvT, it?rad acceaawy oflD; a taidt afire), 3 eaaa t Ity pnta retest agar at dis Web site and we wl prtni& a ww certificate far that 40av- Tlss respow reflects actlre 4wty Sea W' date the w ki algal was fast on active day, 'it was Wkiin elate preceding 367, days. For hkm ieal idbemation, please co mtact the Seavicr S A poits-rte cem et.. btavx ip)6ir*ration on Acd-w Duty Status" Active Jury states as reparted is ibis csstiScate is did 6 accardmtce with 14 L> SC 10l(d)(1) far aperiod cf'mare than 34 cousecu r days. la the ease a£ a member of thr National Gum d, iKhkles serrict wider a ta to acOve ser+ite arxhe &e d by the presi kta tat the Secretary of Defetmsr for a pewd ct more than 30 cousecuthv 's undet 32 USG § 50:(f) for pwposes of respaa&g to a uaoi anal * 3?Y declared by die Pte4deat and dried by Federal Amu A;g Acts Geer d Resrmv (AGR) members aaia be assigned against art mAmitttl mom:.-am posifm i a the emit thca uwpc rt. Tftiis iockuirs Nat-? TARs, 63aaiae Cotes Alts and Coast Gttacd RPM, Acave Duty rAw also qVhn to a Unf hued Sw4ce member -ho is as actor a duty ,cs amrmissime4 pdkxr of Ow US. PuNk 14ft* Service: Qc the'Naooad Oceaaiic tad Atmorpherk A dtd istaa4m (:,%'O Ai' Commissioned Carps) for a parted ofmore thati 34 conseetdt've doys- Coverage UnAer the S L4 is Broader as Sande Coo Coverage tmskr the SCRA is broader a same cases and ioc5ades some eategmrics ofpessaus on acdvvr duty for perposes cfdw SCPA vv wotdd not be reported as on Active Day radix &s certi6cate. Man) times orders am amended to r--ucnd the petted afatiivs ditty, vvbwk would extend SCRA pn ectians- Pets= seems to tely on d is weber certfietificat shoedtl check to make sure the orders on which SCRAi protectiow are based have hat theca wDended to vocad the in k*m dates, of service: F some prawfim d'the SCRA may extend to perstms echo have reached orders to report for actim arty or to be kdoctad, but who have txr actuatfy began active duty; or actually reported far iarhwbou. The Lag Dde on Acme DLly+ entry is ` sqxmist - because a uumbat of - - of SERA rx and br,,aud the elates of active duty, Those who soda rely on that cri cafe at urged to seek quaff kgal coausel to crater drat Al rsgbts gcttaameed m Senice members urAa Ore SCRA are protected. WAILN G_ This tatificak vvas Va6ded based au a name tad SS2i provided try the regwster- PrMift an errouraus mime or SSN veil caw,e an emxwous cx+catetobeprovided, RepottIDNUKD7T$4H3 2;.5293 OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS CUMBERLAND COUNTY PORTFOLIO RECOVERY ASSOCIATES, LLC ) COURT OF COMMON PLEAS CUMBERLAND COUNTY VS. ) DORETHA L WOODS ) NO. 09-5688 To: DORETHA L WOODS 400 6TH ST NEW CUMBERLAND, PA 17070 NOTICE, RULE 237.5 NOTICE OF PRAECIPE TO ENTER JUDGMENT BY DEFAULT Date of Notice: September 24, 2009 IMPORTANT NOTICE YOU ARE IN DEFAULT BECAUSE YOU HAVE FAILED TO ENTER A WRITTEN APPEARANCE PERSONALLY OR BY ATTORNEY AND FILE IN WRITING WITH THE COURT YOUR DEFENSES OR OBJECTIONS TO THE CLAIMS SET FORTH AGAINST YOU. UNLESS YOU ACT WITHIN TEN DAYS FROM THE DATE OF THIS NOTICE, A JUDGMENT MAY BE ENTERED AGAINST YOU WITHOUT A HEARING AND YOU MAY LOSE YOUR PROPERTY OR OTHER IMPORTANT RIGHTS. YOU SHOULD TAKE THIS PAPER TO YOUR LAWYER AT ONCE, IF YOU DO NOT HAVE A LAWYER, GO TO OR TELEPHONE THE OFFICE SET FORTH BELOW. THIS OFFICE CAN PROVIDE YOU WITH INFORMATION ABOUT HIRING A LAWYER. 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 D ID J. APOTHAKER, ESQUIRE AP THAKER & ASSOCIATES, PC A w Firm Engaged in Debt Collection 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorney for Plaintiff Attorney ID #38423 A• FILED -C, cIfrCc .. r'r 11 -4 MgNOV -9 PH ?: "? 414. oo P p ATM Cti.`? 1583'1 i ? ?a?o OFFICE OF THE PROTHONOTARY COURT OF COMMON PLEAS TO: DORETHA L WOODS 400 6TH ST NEW CUMBERLAND, PA 17070 PORTFOLIO RECOVERY ASSOCIATES, LLC Plaintiff vs. DORETHA L WOODS Defendant COURT OF COMMON PLEAS OF CUMBERLAND COUNTY NO.: 09-5688 Civil Action NOTICE Pursuant to Rule 236 of the Supreme Court of Pennsylvania, you are hereby notified that a Judgment has been entered against you in the above proceeding as indicated belo XX JUDGMENT BY DEFAULT JUDGMENT IN REPLEVIN JUDGMENT BY CONFESSION JUDGMENT FOR POSSESSION JUDGMENT ON AWARD OF ARBITRATORS JUDGMENT ON VERDICT JUDGMENT ON COURT FINDINGS JUDGMENT ON WRIT OF REVIVAL IF YOU HAVE ANY QUESTIONS CONCERNING THIS NOTICE, PLEASE CALL: ATTORNEY David J. Apothaker, Esq. at this telephone number: 800-672-0215