HomeMy WebLinkAbout09-8412-Our Isle No.: 224507
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.
GARRETT ROSAS
108 MELBOURNE LANE
MECHANICSBURG, PA 17055
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.. b I ?-( I )-
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
VOur Ale No.: 224507
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.
GARRETT ROSAS
108 MELBOURNE LANE
MECHANICSBURG, PA 17055
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
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 GARRETT ROSAS, an adult individual residing at 108 MELBOURNE
LANE MECHANICSBURG, PA 17055.
3. Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, is the Assignee and Successor in
Interest of Account #5490990997628159; and said account was issued to Defendant(s) by MBNABANK OF
AMERICA, 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 $15,877.45. 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".
1 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
$15,877.45 and requests this Court award costs to the extent permitted by applicable law.
APOTHAKER & AS C TES, P.C.
Attorney fo PI lebt tiA Law Firm Engage in Collectioi
BY:
Dated: 12/2/2009
David I
Our File No.: 224507
0
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
understands that the statements therein are
made subject to the penalties of 18 Pa.C.S.A. 4904
falsification to authorities.
David J. Apc t ker, Esquire
Attorney for Plaintiff
DATE: 12/2/2009
PORTFOLIO RECOVERY ASSOCIATES, LLC
GARRETT ROSAS
108 MELBOURNE LANE
MECHANICSBURG, PA 17055
STATEMENT OF ACCOUNT
Debtor's Name: GARRETT ROSAS
Account Number: 5490990997628159
Original Creditor: MBNA/BANK OF AMERICA
Balance Due: $15,877.45
Our File No.: 224507
EXHIBIT "A"
224507
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:
PORTFOLIO RECOVERY Expiration Date:
ASSOCIATES, LLC
Type of Action:
Civil Action
Defendant/s:
GARRETT ROSAS
Serve Upon:
GARRETT ROSAS
Address for Service:
108 MELBOURNE LANE
MECHANICSBURG, PA 17055
Alternate Address for Service:
Type of Service:
( ) Personal (X) Adult in Charge () Deputize () Certified Mail () 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
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Our File No.: 224507
APOTHAKER & ASSOCIATES, P.C.
BY: David J. Apothaker, Esquire
Attorney I.D.# 38423
520 Fellowship Road C306
Mount Laurel, NJ 08054
(800) 672-0215
Attorney for Plaintiff
PORTFOLIO RECOVERY
ASSOCIATES, LLC
Plaintiff,
vs.
GARRETT ROSAS
Defendant.
20 ~ o F~a 22 ~-~ ~~~ 5 ~
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO. 09-8412
PRAECIPE TO DISMISS WITHOUT PREJ[JDICE
TO THE PROTHONOTARY:
Kindly dismiss this action without prejudice.
APOTHAKER & ASSOCIATES, P.C.
Attorneys for Pl 'tiff
A Law Firm Engaged i~bt Collection
By: ~../
David J. Apoth'alcer, Esquire
Dated: 2/15/2010