HomeMy WebLinkAbout09-8852• Ottr File No.: 231146
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.
HOLLY R BRULIA
14 ALTOONA AVE
ENOLA, PA 17025
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NOTICE
T rIn
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
Out File No.: 231146
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.
HOLLY R BRULIA
14 ALTOONA AVE
ENOLA, PA 17025
Defendant.
COURT OF COMMON PLEAS
CUMBERLAND COUNTY
NO.:
q 5 ? c ,`v . ( tc n?
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 HOLLY R BRULIA, an adult individual residing at 14 ALTOONA AVE
ENOLA, PA 17025.
3. Plaintiff, PORTFOLIO RECOVERY ASSOCIATES, LLC, is the Assignee and Successor in
Interest of Account #5155970002326318; and said account was issued to Defendant(s) by HSBC/ORCHARD
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 $1,644.60. 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
$1,644.60 and requests this Court award costs to the extent permitted by applicable law.
APOTHAKER & A OC TES, P.C.
Attorney f r Pl 'tiff
A Law Firm Eneag d in ebt Corectioi
BY:
Dated: 12/16/2009
David J. Apothake`r, Esquire
Our File No.: 231146
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 belie.
made subject to the penalties of 18 Pa.C.S.A. 4904
David J. Apothaker, Esquire
Attorney for Plaintiff
s that the statements therein are
to authorities.
DATE: 12/16/2009
PORTFOLIO RECOVERY ASSOCIATES, LLC
HOLLY R BRULIA
14 ALTOONA AVE
ENOLA, PA 17025
STATEMENT OF ACCOUNT
Debtor's Name: HOLLY R BRULIA
Account Number: 5155970002326318
Original Creditor: HSBC/ORCHARD BANK
Balance Due: $1,644.60
Our File No.: 231146
EXHIBIT "A"
Off. ?; .. o
fje,4,4 1/35-7/41/
R Thomas Kline
Sheriff
Ronny R Anderson
Chief Deputy
Jody S Smith
Civil Process Sergeant
Edward L Schorpp
Solicitor
-_,G , F .,.? ?";;,,:
2819 JAN -5 PH 21 26
0LWR1-''4U
Portfolio Recovery Associates, LLC
vs. Case Number
Holly R. Brulia 2009-8852
SHERIFF'S RETURN OF SERVICE
12/30/2009 02:05 PM - Mark Conklin, Deputy Sheriff, who being duly sworn according to law, states that on December
30, 2009 at 1405 hours, he served a true copy of the within Complaint and Notice, upon the within named
defendant, to wit: Holly R. Brulia, by making known unto herself personally, at 14 Altoona Avenue, Enola,
Cumberland County, Pennsylvania 17025 its contents and at the same time handing to her personally the
said true and correct copy of the same.
SHERIFF COST: $41.50
SO ANSWERS,
R THOMAS KLINE, SHERIFF
BV y
Deputy Sheriff
o? t ?r,".
SHERIFF'S OFFICE OF CUMBERLAND
OF THE
PRMHWUW
Our File Igo.: 231146
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PORTFOLIO RECOVERY ASSOCIATES,
LLC
Plaintiff
vs.
HOLLY R BRULIA
Defendant
IN THE COURT OF COMMON PLEAS OF
CUMBERLAND COUNTY, PENNSYLVANIA
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NO.: 09-8852 ~ `~ ° ° -~
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PRAECIPE FOR APPOINTMENT OF ARBITRATORS ~ `"
TO THE HONORABLE, THE JUDGES OF SAID COURT:
Benjamin J. Cavallaro, Esquire, counsel for the Plaintiff in the above action, respectfully represents that:
1. The above-captioned action is at issue
2. The claim of Plaintiff in the action is $1644.60.
The following attorneys are interested in the case as counsel or aze otherwise disqualified to sit as abbitrators:
For Defendant For Plaintiff
ATTN: MR. GARY KELLY ESQ Benjamin J. Cavallazo, Esquire
3117 CHESTNUT ST 520 Fellowship Road C306
CAMP HILL, PA 17011 Mount Laurel, N3 08054
(800}672-0215
Attorney for Plaintiff
WHEREFORE, your petitioner prays your Honorable Court to appoint three (3) abbitrators to whom the case shall
be submitted.
July 28, 2010
Respectful bmi J
Benj in J. Taro, Esquire
ORDER OF COURT
AND NOW, , 20 , in consideration of the foregoing petition,
Esq., and Esq.,
and Esq., are appointed arbitrators in the above captioned action
as prayed for.
By the Court,
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o'~ -t~d6/` ~~ v S
Plaintiff
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Defendant
Oath
We do solemnly swear (or affirm) that we will support, obey and defend the Constitution of the United
States the Constitution of this Commonw and th e will discharge the uties of o ice
with f elity.
Sig r Sign a Si ature
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Name (Chairman) Name Name
Law Firm
/9S ~ ~'
Address
~ ~
City, Zip
In The Court of Common Pleaos of Cumberland
County, Pennsylvania No.~/ -J~
Civil Action -Law.
Law Firm
Address
City, Zip
Law ,F,ir(m~
Address
C~.c~-~ 1~ ~~ ~ 70~ ~
City, Zip
Award
We, the undersigned arbitrators, having been duly appointed and sworn (or affirmed), make the
f~llnwin~ award: (Note: If damages for delay are awarded, they shall be separately stated.)
Date of Hearing: ~ /
( a'rman)
Date of Award: ~~ ~~ /~/
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Notice of Entry of Award
Now, the day of ,,~~~=- , 20~~, at ~.'s(> , ~.M., the above award was
entered upon the`dve.1~~~=acid notice thereof given by mail to the parties or their attorneys.
..
Arbitrators' compensation tQ.bepaid-upon appeal: $ ~~~.
By:
Prothonotary Deputy
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Oi~ THE PROTHONOTAR'r'
200 OCT 21 APB 9~ 50
CUMBERLA~dD COUNTY
PEf~N5YLYANIA
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