The URL can be used to link to this page

Home My WebLink About09-7358t Our File No.: 2013 71 APOTHAKER & ASSOCIATES, P.C. BY: David J. Apothaker, Esquire, Esq. Attorney I.1)438423 520 Fellowship Road C306 Mount Laurel, NJ 08054 (800) 672-0215 Attorneys for Plaintiff FORTIS CAPITAL LLC c/o Apothaker & Associates, P.C 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. SHELLEY JONES A/K/A SHELLEY KRAFT 604 THIRD ST NEW CUMBERLAND, PA 17070 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: bq- `1358 &"J i ( -er 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.: 201371 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 FORTIS CAPITAL LLC c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, VS. SHELLEY JONES A/K/A SHELLEY KRAFT 604 THIRD ST NEW CUMBERLAND, PA 17070 Defendant. COURT OF COMMON PLEAS CUMBERLAND COUNTY NO.: 09- '73-6? 04"?-4 -T?- CIVIL ACTION COMPLAINT FIRST COUNT I. Plaintiff is FORTIS CAPITAL LLC c/o Apothaker & Associates, P.C., 520 Fellowship Road C306, Mount Laurel, NJ 08054. 2. Defendant(s) is/are SHELLEY JONES A/K/A SHELLEY KRAFT, an adult individual residing at 604 THIRD ST NEW CUMBERLAND, PA 17070. 3. Plaintiff, FORTIS CAPITAL LLC, is the Assignee and Successor in Interest of Account #7021270342500989; and said account was issued to Defendant(s) by BEST BUY, 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 $3,041.50. 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 $3,041.50 and requests this Court award costs to the extent permitted by applicable law. APOTHAKER & Attorney A Law Firm En2as BY: Dated: 10/20/2009 David J. RTES, P.C. Collection Our File No.: 201371 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 relatigg-0 unworn falsification to authorities. David Jk pethaker,Esq? Atto ev for Plaintiff DATE: 10/20/2009 FORTIS CAPITAL LLC SHELLEY JONES A/K/A SHELLEY KRAFT 604 THIRD ST NEW CUMBERLAND, PA 17070 STATEMENT OF ACCOUNT Debtor's Name: SHELLEY JONES A/K/A SHELLEY KRAFT Account Number: 7021270342500989 Original Creditor: BEST BUY Balance Due: $3,041.50 Our File No.: 201371 EXHIBIT "A" 201371 Request for Service R. Thomas Kline Sheriff Cumberland County Office of the Sheriff One Courthouse Square Carlisle, PA 17013 Ph: 717.240.6390 Fx: 717-240-6397 Plaintiffs: Court Number: FORTIS CAPITAL LLC Expiration Date: Type of Action: Civil Action Defendant/s: SHELLEY JONES A/K/A SHELLEY KRAFT Serve Upon: SHELLEY JONES A/K/A SHELLEY KRAFT Address for Service: 604 THIRD ST NEW CUMBERLAND, PA 17070 Alternate Address for Service: Type of Service: ( ) Personal (X) Adult in Charge O Deputize O Certified Mail O Posting Special Service Instructions: ** If service is to be made by deputized service to another county please specify which county Filing Attorney Information: Name: Apothaker & Associates, P.C. Address: 520 Fellowship Road C306 Mount Laurel, NJ 08054 Telephone: 215-634-8920 ` Out File No.: 232042 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 AMERICAN EXPRESS CENTURION BANK c/o Apothaker & Associates, P.C. 520 Fellowship Road C306 Mount Laurel, NJ 08054 Plaintiff, vs. COURT OF COMMON PLEAS CLINTON -COUNTY NO.. JONATHAN TEMPLE 894 HERR ST LOCK HAVEN, PA 17745-3012 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. COURT ADMINISTRATOR COURT OF COMMON PLEAS OF CLINTON COUNTY COURTHOUSE LOCK HAVEN, PA 17745 717-893-4016 0 OF 4P 17 mTw 2009 OCT 26 PM 2: to COUNTY PEP`dNSYLVAN'A 78.50 PA -ATty e d3a !sgq Sheriffs Office of Cumberland County R Thomas Kline Sheri Ronny R Anderson Chief Deputy Jody S Smith Civil Process Sergeant Edward L Schorpp Solicitor If"$"rtr Iataber???? OFflc£ OF THE $-ERIFF HEED-?t: FFK"IPE OF T}!= - ' , ,r') ' Y 2009 NOV -6 Pig 2: S7 CIt"Vr ? .? 'vTY Fortis Capital LLC vs Case Number . Shelley Jones 2009-7358 SHERIFF'S RETURN OF SERVICE 10/28/2009 01:33 PM - Ron Hoover, Deputy Sheriff, who being duly sworn according to law, states that on October 28 2009 at 1333 hours, he served a true copy of the within Complaint and Notice, upon the within named defendant, to wit: Shelley Jones, by making known unto Stephen Klase, adult in charge at 238 Poplar Avenue New Cumberland, Cumberland County, Pennsylvania 17070 its contents and at the same time handing to him personally the said true and correct copy of the same. SHERIFF COST: $58.60 SO ANSWE , ?? October 29, 2009 R THOMAS KLINE, SHERIFF Deputy Sheriff