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Our File No.: 218834
APOTHAKEIR & 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
RJM ACQUISITIONS LLC
c/o Apothaker & Associates, P.C.
520 Fellowship Road C306
Mount Laurel, NJ 08054
Plaintiff,
vs.
CHERYL REYNOLDS
12 IAN DR
MOUNT HOLLY SPRINGS, PA 17065
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.. 09 - 94(05 Civ c Iet
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.: 218834
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
RJM ACQUISITIONS LLC
c/o Apothaker & Associates, P.C.
520 Fellowship Road C306
Mount Laurel, NJ 08054
Plaintiff,
VS.
CHERYL REYNOLDS
12 IAN DR
MOUNT HOLLY SPRINGS, PA 17065
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.:
CIVIL ACTION COMPLAINT
FIRST COUNT
1. Plaintiff is RJM ACQUISITIONS LLC c/o Apothaker & Associates, P.C., 520 Fellowship Road
C306, Mount Laurel, NJ 08054.
2. Defendant(s) is/are CHERYL REYNOLDS, an adult individual residing at 12 IAN DR MOUNT
HOLLY SPRINGS, PA 17065.
3. Plaintiff, RJM ACQUISITIONS LLC, is the Assignee and Successor in Interest of Account
4081010167682648; and said account was issued to Defendant(s) by WACHOVIA 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 $1,401.68. 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
$1,401.68 and requests this Court award costs to the extent permitted by applicable law.
APOTHAKER & ASSOCIATES, P.C.
Attorney for Pl
A Law Firm Engaged ' De t Collection
BY:
Dated: 8/24/2009
David J. A
Our File No.: 218834
VERIFICATION
David J. Apothaker, Esquire hereby states that I am counsel for plaintiff in this action, an d 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 relatir t? nsworn falsification to authorities.
David J. othaker, Esquire
Attome for Plaintiff
DATE: 8/24/2009
RJM ACQUISITIONS LLC
CHERYL REYNOLDS
12 IAN DR
MOUNT HOLLY SPRINGS, PA 17065
STATEMENT OF ACCOUNT
Debtor's Name: CHERYL REYNOLDS
Account Number: 081010167682648
Original Creditor: WACHOVIA BANK
Balance Due: $1,401.68
Our File No.: 218834
EXHIBIT "A"
0
O. THE ^TA.RY
Sep2QG9 AWf A 8: 4 9
Cup
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41S. 5o Po ATW
Cet I UID
W* asoo-ag
Sheriffs Office of Cumberland County
R Thomas Kline
Sheri
Ronny R Anderson
Chief Deputy
Jody S Smith
Civil Process Sergeant
Edward L Schorpp
Solicitor
OF THEE f;-!7 OTAPY
2009 SEP I I AM 8* 4 3
`iuMrS ' . _.lN'i Y
RJM Acquisitions LLC
vs.
Cheryl Reynolds
Case
SHERIFF'S RETURN OF SERVICE
09/10/2009 08:30 AM - Shannon Shertzer, Deputy Sheriff, who being duly sworn according to law, states that b
September 10, 2009 at 0830 hours, he served a true copy of the within Complaint and Notice, upon the
within named defendant, to wit: Cheryl Reynolds, by making known unto herself personally, at The
Cumberland County Sheriffs Office 1 Courthouse Square Room 303 Carlisle, Cumberland County,
Pennsylvania 17013 its contents and at the same time handing to her personally the said true andorre
copy of the same.
SHERIFF COST: $34.30
September 10, 2009
SO ANSWERS,
R THOMAS KLINE, SHERIFF
r'
By
Deput Sheri f
r
Our file No.: 218834
APOTHAKER & ASSOCIAT S, P.C.
520 Fellowship Road C306
Mount Laurel, NJ 08054
(800) 672-0215
Attorneys for Plaintiff
Attorney ID# 55140
COURT OF COMMON PLEAS
RJM ACQUISITIONS LLC ) CUMBERLAND COUNTY
Plaintiff, ) DOCKET NO.: 09-5965
VS. )
CHERYL REYNOLDS ) Civil Action
STIPULATION IN LIEU OF JUDGMENT
Defendant. )
The matters and things in controversy having been discussed by and between the
parties, and a settlement having been agreed upon:
It is on September 16, 2009, STIPULATED by and between Plaintiff, RJM
ACQUISITIONS LLC, and Defendant, CHERYL REYNOLDS parties as follows:
1. Defendant agrees to pay the sum of $1,585.15, which sum Plaintiff agrees
to accept in full settlement of its claim herein, inclusive of counsel fees and court costs.
2. The sum aforesaid of $1,585.15 shall be paid by the by Defendant,
CHERYL REYNOLDS, to the attorneys for Plaintiff in the following manner:
a. $476.00 to be paid on or before September 22, 2009;
b. $100.00 to be paid bi-weekly, beginning October 6, 2009 until paid in
full.
All checks are to made payable to RJM ACQUISITIONS LLC, and sent
to:
Apothaker & Associates, P.C.
520 Fellowship Road C306
Mount Laurel, NJ 08054
? SE' 2 3 2009 ? U
Our file No.: 218834
3. In the event Defendant fails to pay in accordance with the terms set forth
in this Stipulation, then, and in that event, Plaintiff shall be entitled to obtain the entry of
Judgment against Defendant ex parte, in the sum of $1,585.15, giving Defendant credit
for any sums actually paid pursuant to the terms of this Stipulation.
4. In the event of default as aforesaid, and default is not cured within ten (10)
days, Plaintiff shall be entitled to obtain the entry of Judgment upon ex parte application,
with supporting certification, and with notice to Defendant only in the form of a copy of
the application addressed to CHERYL REYNOLDS by first-class, postage prepaid.
We hereby consent to the form and entry of the within Stipulation.
APOTHAKER & ASSOCIATES, P.C.
Attorneys for Pl? i
A Law Firm Engaged' ebt Collection
By:
Kim rly F. Scian, Esquire
OF T , 11'?,
2009 Sc? 28 N 3: 2i
iA,